QUALITY ASSURANCE SAMPLING PLAN FOR ECTOR DRUM SITE ... · quality assurance sampling plan (QASP)...

QUALITY ASSURANCE SAMPLING PLAN

FOR

Ector Drum Site

Removal Support

Odessa, Ector County, Texas

Prepared For

U.S. Environmental Protection Agency Region 6

1445 Ross Ave. Dallas, Texas 75202

Prepared by

CSS-Dynamac 1323 Columbia Drive, Suite 307

Richardson, Texas 75081

Date Prepared May 15, 2015

CERCLIS Number TBD

TDD Number 1/DYNAMAC-077-15-001

Contract Number EP-W-06-077

START-3 Project Manager Noel Biscocho

Telephone No. 214-575-3344

U.S. EPA On-Scene Coordinator

Bill Rhotenberry

Mike McAteer

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QUALITY ASSURANCE SAMPLING PLAN

FOR

Ector Drum Site

Removal Support

Odessa, Ector County, Texas

Prepared For

U.S. Environmental Protection Agency Region 6

1445 Ross Ave. Dallas, Texas 75202

Prepared by

CSS-Dynamac 1323 Columbia Drive, Suite 307

Richardson, Texas 75081

May 15, 2015

APPROVALS

CSS-Dynamac U.S. Environmental Protection Agency

____________________________ Noel Biscocho Bill Rhotenberry START-3 Project Manager On-Scene Coordinator CSS-Dynamac U.S. Environmental Protection Agency

____________________________ Debra Pandak Mike McAteer START-3 Program Manager On-Scene Coordinator

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mmcateer

New Stamp

brhotenb

BRhotenberry

CSS-Dynamac May 15, 2015

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TABLE OF CONTENTS

PAGE #

1.0 INTRODUCTION .............................................................................................................. 1

1.1 OBJECTIVES ........................................................................................................ 1

2.0 SITE BACKground ........................................................................................................... 1

2.1 Site Location and Owner ..................................................................................... 1 2.2 Site History ............................................................................................................ 2

3.0 FIELD OPERATIONS ...................................................................................................... 3

3.1 CONCEPT OF OPERATIONS ........................................................................... 3 3.1.1 Schedule ................................................................................................... 3 3.1.2 Health and Safety .................................................................................... 4 3.1.3 Site Access and Logistics ....................................................................... 4

3.2 SAMPLING DESIGN ........................................................................................... 4 3.2.1 Soil Sampling ............................................................................................ 4 3.2.2 Waste Sampling ....................................................................................... 5

3.3 SAMPLE LOCATIONS ........................................................................................ 6 3.4 SAMPLE COLLECTION ...................................................................................... 6

3.4.1 Soil Sampling ............................................................................................ 6 3.4.2 Waste Sampling ....................................................................................... 6

3.5 CONTROL OF CONTAMINATED MATERIALS ............................................. 6 3.6 ANALYTICAL PARAMETERS ........................................................................... 7

4.0 QUALITY CONTROL ....................................................................................................... 7

4.1 LABORATORY QUALITY CONTROL .............................................................. 7 4.2 FIELD QUALITY CONTROL .............................................................................. 7 4.3 CHAIN OF CUSTODY ......................................................................................... 7

5.0 RECONCILIATION WITH DATA QUALITY OBJECTIVES ....................................... 7

6.0 DELIVERABLES AND PROJECT ORGANIZATION .................................................. 8

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Ector Drums Removal Quality Assurance Project Plan Final

ii

TABLE OF CONTENTS (Continued)

FIGURES Figure 1 Site Location Map Figure 2 Aerial Site Location Map TABLES Table 1 Sample Collection Summary Table 2 Sampling and Analysis Summary Table 3 Proposed Sample Locations Table 4 Data Quality Objectives APPENDICES Appendix A TCEQ Investigation Report Appendix B Drinking Water Survey Report and Water Well Inventory Appendix C EPA ERT SOP 2012 Soil Sampling Appendix D EPA ERT SOP 2009 Drum Sampling Appendix E EPA ERT SOP 2002 Sample Documentation Appendix F EPA ERT SOP 2049 Investigation-Derived Waste Management

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1 This document was prepared by CSS-Dynamac expressly for EPA. It shall not be released or disclosed in whole or in part without the express, written permission of EPA.

1.0 INTRODUCTION

CSS-Dynamac Superfund Technical Assessment and Response Team (START-3) has been

tasked by the U.S. Environmental Protection Agency (EPA), Region 6, under Technical

Direction Document (TDD) # 1/DYNAMAC-077-15-001, to collect samples in support of the

Removal activities to be conducted at the Ector Drum Site, located at 2604 N. Marco Ave.,

Odessa, Ector County, Texas (TX).

The focus of this investigation is to collect surface soil and waste samples at the site to

determine the presence of hazardous substances and document whether site conditions

present an imminent and substantial endangerment to human health and the environment. This

quality assurance sampling plan (QASP) is prepared in partial fulfillment of the TDD. This QASP

is designed to guide field operations during the collection of soil and waste (sludge and/or liquid)

samples and to describe the quality assurance/quality control (QA/QC) measures and

procedures that will be implemented during field work.

1.1 OBJECTIVES

The objective of this project, per EPA OSC, is as follows:

Collect soil and waste (sludge or liquid) on-property to determine the presence or absence

of hazardous substances.

Document site conditions to determine the potential of offsite migration of hazardous

substances.

To accomplish the above-mentioned objectives, START will collect up to ten (10) surface soil

samples from locations identified by the EPA OSC’s; and collect up to four (4) waste samples

(sludge or liquid) from drums or tote-containers located on-property.

2.0 SITE BACKGROUND

2.1 Site Location and Owner

Ector Drum Site is a former drum reconditioning facility located at 2604 N. Marco Ave.,

Odessa, Ector County, Texas (TX). Geographic coordinates for the site (obtained via

Google Earth), from the on-property office, are: 31.885702º N latitude and -102.294767º

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W longitude (Figure 1). The approximate size of the property (measured from Google

Earth) is 4.53 acres or 197,333.5 square feet (sq. ft.).

The site is situated in an urban setting, with industrial, commercial, and residential

properties located within a 1/8 mile radius of the property (Figure 2). Ector Drum site is in

the northeast corner of N. Marco Ave and E. Market St., and is surrounded by

commercial/industrial properties (Figures 1 and 2).

The property appears to be bordered by a chain link fence. However, a Texas

Commission on Environmental Quality (TCEQ) Investigation Report on 7/25/14 reported

that there were numerous openings throughout the fence line (Appendix A).

Ector Drum is an abandoned facility owned by Mr. Randy Beard.

2.2 Site History

There is very little data pertaining to past operations. The date when operations began is

not currently known. The date the site was abandoned is not known; however, the site

was inactive and abandoned on July 25, 2014, when the TCEQ conducted an

investigation at the site. The TCEQ investigation was the result of a complaint received

by the TCEQ Region 7 office in Midland, TX on June 23, 2014. The complaint alleged

that contaminated storm water was being discharged from the facility. The site visit

conducted on July 25, 2014 indicated that numerous 55-gallon metal and plastic drums

and 350-gallon tote-containers full of unknown chemicals existed at the facility. The

TCEQ inspectors noted many stained soil areas throughout the site. Two waste above-

ground storage tanks (ASTs), designated as Fac 001 and Fac 002, were observed within

a concrete secondary containment vault. AST Fac.001 had an estimated total capacity of

200 barrels (bbls) and the AST Fac. 002 had an estimated total capacity of 160 bbls. The

TCEQ inspectors noted that the secondary containment vault contained a mixture of water

and unknown chemical. Approximately 6 to 8 inches of freeboard remained in the

secondary containment vault.

On October 8, 2014, a contractor for TCEQ located the on-site drinking water well

(Appendix B). Using an interface probe to gauge the well for the presence of Phase

Separated Hydrocarbons (PSHs), 1.8 feet of PSHs existed in the well bore. The

investigators believed that the PSH (oil) migrated into the well casing through an electric

conduit. The source of the oil is believed to be surface water runoff impacted by releases

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of oil from drums/containment areas located at the site. The TCEQ contractors built a

small concrete berm around the drinking water well to prevent additional impacts from

future rainfall events. Two samples were collected from the on-site drinking water well: an

oil-phased sample and a water-phased sample. Both samples were submitted to a

laboratory for total metals (EPA Method 6010), volatile organic compounds (VOCs) using

EPA Method 8260, semi-volatile organic compounds (SVOCs) using EPA Method 8270,

and Total Petroleum Hydrocarbons (TPH) using TX Method 1005 and 1006. Inorganic

chemical analysis of the oil-phased groundwater sample indicated concentrations of

arsenic (2.46 milligrams per liter [mg/L]), chromium (33.1 mg/L), copper (5.0 mg/L), lead

(3.34 mg/L), nickel (2.92 mg/L) and zinc (274 mg/L), all of which exceeded the TCEQ Risk

Reduction Program (TRRP) Tier I, Residential Groundwater Protective Concentration

Levels (PCLs). Organic chemical analysis of the oil-phased groundwater sample indicated

the presence of benzene at 2.90 mg/L, which exceeded the TRRP Tier 1 Residential

Groundwater PCLs. Due to dilution factor of 1000, there were no other VOCs or SVOCs

detected above the detection limit. TPH analysis (TX 1005) of the oil-phased groundwater

sample indicated 533,000 mg/L. TPH analysis (TX1006) indicated exceedances of the

TRRP Tier I, Residential Groundwater PCLs for aliphatic hydrocarbons in the C12-16,

C16-C21, and C21-35 range.

Inorganic analysis of the water-phased groundwater sample indicated concentrations of

chromium (0.298 mg/L), mercury (0.00211 mg/L) and zinc (7.41 mg/L) exceeding the

TRRP Tier 1 Residential Groundwater PCLs. Organic chemical analysis did not detect

the presence of VOCs and SVOCs in concentrations exceeding the TRRP Tier 1

Residential Groundwater PCLs. TPH analysis (TX1005) indicated 274 mg/L of TPH in the

water-phase groundwater sample.

3.0 FIELD OPERATIONS

3.1 CONCEPT OF OPERATIONS

3.1.1 Schedule

A site walk-through with the EPA OSCs, TCEQ Representatives and START-3 team

is scheduled on May 19, 2015. The field work and sample packaging is scheduled

to commence on May 20, 2015, and is anticipated to require approximately 1 day for

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completion. Samples are to be packaged and hand-delivered to Xenco laboratory on

May 20, 2015.

Preliminary laboratory analytical results are anticipated to be received by START-3

within five (5) business days of sample receipt by the laboratory. The final laboratory

analytical report package is anticipated to be received within 10 business days.

3.1.2 Health and Safety

Field activities will be conducted in accordance with EPA Standard Operating

Procedures (SOPs), the Generic QAPP, and a site-specific Health and Safety Plan

(HASP).

3.1.3 Site Access and Logistics

The EPA OSCs will obtain site access from the current site owner. All activities will

be coordinated with the EPA OSCs and TCEQ.

3.2 SAMPLING DESIGN

Table 1 presents the estimated number of samples, location descriptions, and laboratory

analyses. The sampling design includes the collection of samples at one (1) to ten (10)

soil locations on-site, and one (1) to four (4) waste samples (liquid or sludge) from one (1)

to four (4) selected drums and/or tote-containers. Dedicated sampling equipment will be

used wherever possible in an effort to eliminate any potential cross contamination

concerns. All sampling activities will be documented in a logbook and photographed in

accordance with EPA ERT SOP #2002 (Appendix E).

Samples will be packaged and hand-delivered to Xenco Laboratory in Odessa, Texas.

Laboratory analytical methods are specified in Table 2.

3.2.1 Soil Sampling

START will collect soil samples from one (1) to ten (10) locations as specified by the

EPA OSC and selected during the walk-through. Grab samples will be collected at

a depth of approximately 0 to 6 inches below ground surface using a stainless steel

spoon or trowel, per the procedures in ERT SOP 2012 Soil Sampling (Appendix C).

Soil VOC sample aliquots will be collected in 5 gram zero-headspace Encore™

sampling devices. Sample containers are listed in Table 2. The surface soil

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samples collected will be sequentially labeled with the site, type of sample and

number, e.g., ED-S01 = Ector Drum soil sample 01.

The samples will be shipped to the appropriate laboratory for chemical analysis for

Target Compound List (TCL) VOCs, SVOCs, Pesticides, PCBs, Target Analyte List

(TAL) Total Metals (including mercury and cyanide), and TPH by TX 1005 method.

All sampling activities will be documented in a logbook and photographed.

3.2.2 Waste Sampling

START will collect waste samples (liquid or sludge) from one (1) to four (4)

containers (tote, or 55-gal steel or poly drum) located on-property. Table 1 presents

the anticipated number of container samples, location descriptions, and proposed

laboratory analyses. Dedicated sampling equipment will be used wherever possible

in an effort to eliminate any potential cross contamination concerns.

The container samples will be collected according to ERT SOP 2009 Drum

Sampling (Appendix D). The container samples collected will be sequentially

labeled with the site, type of sample and number, e.g., ED-WS01 = Ector Drum

Waste Sludge 01; ED-WL01 = Ector Drum Waste Liquid 01.

The container samples will be shipped to the appropriate laboratory for chemical

analysis for TCLVOCs, SVOCs, Pesticides, PCBs, TAL Total Metals (including

mercury and cyanide), flashpoint (liquid samples only), TPH by TX 1005

methodology.

In addition, START may collect container samples for hazard categorization.

Hazard categorization will include the use of SPILFYTER strips to test for pH, the

presence of an oxidizing risk, the presence of a fluoride risk, the presence of an

organic solvent in a petroleum compound, the presence of iodine, bromide, and

chloride risks. In addition, flammability risk will be determined on the collected liquid

waste samples.

All waste sampling and hazard categorization activities will be documented in a

logbook and photographed.

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3.3 SAMPLE LOCATIONS

Soil and waste samples will be collected on-property at locations determined during the

site walk-through with the EPA OSCs and START-3 on May 19, 2015.

3.4 SAMPLE COLLECTION

3.4.1 Soil Sampling

Grab samples will be collected at a depth of approximately 0 to 6 inches below

ground surface, using stainless steel spoons or trowels, per the procedures in ERT

SOP 2012 Soil Sampling (Appendix C). Soil VOC sample aliquots will be collected

in 5 gram zero-headspace Encore™ sampling devices. The sample will be

transferred to sample containers. After retrieval, the samples will be labeled,

entered into the SCRIBE database, printed onto a SCRIBE-generated chain-of

custody form, and placed in a cooler, sealed, and shipped to the laboratory for

analysis.

3.4.2 Waste Sampling

Waste samples (liquid) will be collected using either a drum thief from an opening of

a tote-container or 55-gallon drum. Waste samples (sludge) will be collected using a

glass beaker from an opening of a tote or 55-gallon drum or from a stainless steel

trowel or spoon. The samples will be collected according to ERT SOP 2009 Drum

Sampling (Appendix D).

After retrieval, the samples will be labeled, entered into the SCRIBE database,

printed onto a SCRIBE-generated chain-of custody form, and placed in a cooler,

sealed, and shipped to the laboratory for analysis.

3.5 CONTROL OF CONTAMINATED MATERIALS

Any investigation derived waste (IDW) generated through sampling operations will be

contained in accordance with EPA ERT SOP 2049 Investigation-Derived Waste

Management (Appendix F). It is anticipated that IDW will consist of used PPE and used

sampling equipment which does not require special disposal requirements. Upon OSC

direction, the generated IDW will be double-bagged and left on-property until the Removal

begins. At that time, the Emergency Response and Remedial Services (ERRS) contractor

will dispose of the generated IDW at a state-permitted and licensed disposal facility.

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3.6 ANALYTICAL PARAMETERS

The analytical methods are specified in Table 2.

4.0 QUALITY CONTROL

4.1 LABORATORY QUALITY CONTROL

Specific QC criteria have been developed to ensure that the Data Quality Objectives

(DQOs) are met. Analytical methods for sample analysis have been selected on the basis

of the required detection limits, known contaminants existing in the study area, and the

range of analytes to be determined. Table 2 of this text presents method numbers and

reference guidance, sample containers, sample volume requirements, sample

preservatives, and holding times.

4.2 FIELD QUALITY CONTROL

All samples will be handled and preserved as described in CSS-Dynamac SOPs. It is

anticipated that all sampling equipment will be dedicated.

4.3 CHAIN OF CUSTODY

After the samples have been collected, the sampling data (station number, time collected,

sampler, GPS coordinates, etc.) will be entered into U.S. EPA SCRIBE Enterprise

software. SCRIBE Enterprise will be used to generate sample labels and Chain-of-

Custody (COC) forms for the collected samples to be shipped to the laboratory for

chemical analysis. In addition, SCRIBE Enterprise will serve as the sampling and

analytical result database for all the samples collected during the sampling event. All

COCs will be completed according to the EPA ERT SOP #2002 (Appendix E).

5.0 RECONCILIATION WITH DATA QUALITY OBJECTIVES

The data will be assessed for accuracy, precision, completeness, representativeness, and

comparability. Data assessment criteria are presented in the START-3 Generic QAPP, Section

4.0 “Assessment and Oversight” and Section 5.0, “Data Validation and Usability.” Generally,

data that do not meet the established acceptance criteria are cause for re-sampling and re-

analysis. However, in some cases, data that do not meet acceptance criteria are usable with

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specified limitations. Data that are indicated as usable with limitations will be included in the

final report, but will be clearly indicated as having limited usability. Indicators of data limitations

include data qualifiers, quantitative evaluations, and narrative statements regarding potential

bias.

6.0 DELIVERABLES AND PROJECT ORGANIZATION

At the completion of field activities and receipt of validated laboratory analytical data, a sampling

activities report will be submitted to the EPA. The sampling activities report will document all

pertinent sampling activities and the results of sample analyses.

The EPA OSCs, Mike McAteer and Bill Rhotenberry, will provide overall direction for this project

and will identify sampling needs, determine the sampling schedule, and coordinate community

relations.

The START-3 Project Manager (PjM), Noel Biscocho is the primary contact with the EPA. The

START-3 PjM is responsible for project team organization, supervision of all project tasks,

monitoring and documenting the quality of all work produced by the project team, determining

deviations from the QASP, and assisting with the overall sampling effort. The analytical results

of the samples collected will be verified and qualified by a chemist with CSS-Dynamac.

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This document was prepared by CSS-Dynamac expressly for EPA. It shall not be released or disclosed in whole or in part without the express, written permission of EPA.

FIGURES

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_̂

US EPA Region 6START-3

Figure 1. Site Location Map for Ector Drum Site

2604 N. Marco Avenue, Odessa, Ector County, TX 79762

TDD No. 1/Dynamac-077-15-001 SSID No. A6KSCERCLIS No. TBD

.0 2,000 4,0001,000 Feet

1:24,000

Map of Texas

Source: 2013 National Geographic Society (Odessa NE Quadrangle)

Legend

_̂ Ector Drum Site

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_̂

US EPA Region 6START-3

TDD No. 1/Dynamac-077-15-001 SSID No. A6KSCERCLIS No. TBDSource of Imagery: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX,Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community. (Downloaded 5/12/2015)

.0 1,500 3,000750 Feet

1:18,000

Map of Texas

Figure 2. Aerial Site Location Mapfor Ector Drum Site

2604 N. Marco AvenueOdessa, Ector County, TX 79762

Legend

_̂ Ector Drum Site

I-20 Business Loop

Interstate 20

Loop 338

TX-191

N Marco Ave

Eastridge Rd

Rocky Lane Rd

TX-588

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nbiscocho

Typewritten Text



TABLES

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TABLE 1 SAMPLE COLLECTION SUMMARY

Sample Matrix

Sample Location

Analyses Composites or Grab Samples

Trip Blank Samples

MS/MSD Field Duplicates

Rinsates

On-property Surface Soil

1 to 10 locations

TCL VOAs, SVOAs Pesticides and

PCBs, TAL Metals/Hg/CN,

TPH, and Flashpoint

Grab None 1 per 20 samples

1 per 10 samples

NA

On-property Waste (liquid)

1 to 4 locations



TPH, and Flashpoint

Grab None NA NA NA

On-property Waste (solids

/sludge)

1 to 4 locations



TPH, and Flashpoint

Grab None NA NA NA

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TABLE 2 SAMPLING and ANALYSIS SUMMARY

Matrix Analytical Parameter

Analytical Method

Containers (Number, Size, and

Type)

Preservation Requirements

No. of Samples

No. Field Duplicates

No. MS/MSD

Pairs

No. of Equipment

Rinsate Samples

No. of Trip

Blanks

Total Number of Samples to

Lab*

Surface Soil

TCL SVOAs Pesticides, and PCBs, TAL Metals/Hg/CN; TPH

SW846 (8270C, 8081A, 8082, Metals-ICP, 7471A, 9010C/901), TPH: TX-1005

Organics: 1, 8 oz. wide mouth jar;

Inorganics: 1, 8 oz.

wide mouth jar

Organics: Cool to 4oC

Inorganics: Cool to 4°

10 1 1 0 0 11

Surface Soil TCL VOAs SW846 (8260B) (3) 5-gram Encore™

samplers Cool to 4oC 10 1 1 0 0 11

Waste (liquid)

TCL VOAs TCL SVOAs Pesticides, and PCBs, TAL Metals/Hg/CN; TPH

SW846 (8260B) SW846 (8270C, 8081A, 8082, Metals-ICP, 7471A, 9010C/901), TPH: TX-1005



wide mouth jar



4 0 0 0 0 4

Waste (sludge)

TCL VOAs TCL SVOAs Pesticides, and PCBs, TAL Metals/Hg/CN; TPH

SW846 (8260B) SW846 (8270C, 8081A, 8082, Metals-ICP, 7471A, 9010C/901), TPH: TX-1005



wide mouth jar



4 0 0 0 0 4

Notes: *Total number of samples to the laboratory does not include MS/MSD samples. However, please note that MS/MSD or spike/duplicate analysis may require additional sample volume. (X) Number of optional samples that may be collected; samples may be sediments or soils.

KEY

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ºC - Degrees Celsius CLP – Contract Laboratory Program HNO3 – Nitric Acid MS/MSD – Matrix Spike/Matrix Spike Duplicate N/A – Not applicable NaOH – Sodium Hydroxide SOW – Statement of Work TCL – Target Compound List TAL – Target Analyte List

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TABLE 3 Proposed Sample Locations

Sample ID Sample Location Sample Type ED-S01 To Be Determined Soil

ED-S02 To Be Determined Soil ED-S03 To Be Determined Soil

ED-S04 To Be Determined Soil ED-S05 To Be Determined Soil ED-S06 To Be Determined Soil ED-S07 To Be Determined Soil ED-S08 To Be Determined Soil ED-S09 To Be Determined Soil ED-S010 To Be Determined Soil ED-WS01 To Be Determined Waste (sludge)

ED-WS02 To Be Determined Waste (sludge) ED-WS03 To Be Determined Waste (sludge) ED-WS04 To Be Determined Waste (sludge) ED-WL01 To Be Determined Waste (liquid) ED-WL02 To Be Determined Waste (liquid) ED-WL03 To Be Determined Waste (liquid) ED-WL04 To Be Determined Waste (liquid)

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Table 4 DATA QUALITY OBJECTIVES

Ector Drum Site STEP 1. STATE THE PROBLEM Determine if CERCLA hazardous substances are present in the surface soils and containers at the site and document if site conditions present an imminent and substantial endangerment. STEP 2. IDENTIFY THE DECISION If CERCLA hazardous substances are present in the surface soil and containers at the site, and conditions exist for offsite migration the site is eligible for a CERCLA Removal action. If CERCLA hazardous substances are not present in the surface soil or containers at the site, the site may not be eligible for a CERCLA removal action. IDENTIFY THE ALTERNATIVE ACTIONS THAT MAY BE TAKEN BASED ON THE DECISIONS.

If CERCLA hazardous substances are found in the surface soil or containers at the site, a CERCLA Removal action can occur. If CERCLA hazardous substances are not found in the surface soils or containers on-site, a CERCLA Removal action may not be warranted; thus an OPA Removal may be considered.

STEP 3. IDENTIFY INPUTS TO THE DECISION IDENTIFY THE INFORMATIONAL INPUTS NEEDED TO RESOLVE A DECISION.

Surface soil samples and waste samples from the containers located on site.

IDENTIFY THE SOURCES FOR EACH INFORMATIONAL INPUT AND LIST THE INPUTS THAT ARE OBTAINED THROUGH ENVIRONMENTAL MEASUREMENTS.

National Contingency Plan (NCP) All sample results are environmental measurements.

BASIS FOR THE CONTAMINANT SPECIFIC ACTION LEVELS.

NCP, sample CRQLs and CRDLs; TRRP Tier I Commercial/Industrial Protective Cleanup Levels (PCLs)

IDENTIFY POTENTIAL SAMPLING TECHNIQUES AND APPROPRIATE ANALYTICAL METHODS.

On-Site surface soils – Surface soil samples will be collected using dedicated stainless steel trowels or spoons Surface soil samples will be analyzed for TCL VOCs, SVOCs, Pesticides, PCBS, ; TAL Total Metals/Mercury/Cyanides using EPA methods and Total Petroleum Hydrocarbons (TPH)by TX 1005 method utilized by a START-procured Laboratory On-site Containers: Liquids from drums or totes will be collected with either drum thieves or plastic beakers. The liquid waste samples will be analyzed for TCL and TAL components, TPH, and Flashpoint using a START-procured laboratory. On-site Containers: Solids/Sludges will be collected with the use of dedicated trowels and/spoons. The solids/sludges will be analyzed for TCL and TAL constituents, and TPH by a START-procured laboratory.

STEP 4. DEFINE THE BOUNDARIES OF THE STUDY

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Ector Drum Site DEFINE THE DOMAIN OR GEOGRAPHICAL AREA WITHIN WHICH ALL DECISIONS MUST APPLY.

All collected surface soil samples and container waste samples will be collected from the Ector Drum site property.

SPECIFY THE CHARACTERISTICS THAT DEFINE THE POPULATION OF INTEREST.

The primary population of interest are those individuals who work directly adjacent to the site and transient populations.

DEFINE THE SCALE OF THE DECISION MAKING.

Bounds of the samples collected.

DETERMINE THE TIMEFRAME TO WHICH THE DATA APPLY.

Results from this and subsequent potential investigations.

DETERMINE WHEN TO COLLECT THE DATA.

Sample collection will be conducted on May 20, 2015.

IDENTIFY PRACTICAL CONSTRAINTS ON DATA COLLECTION.

EPA/START must obtain access agreements from property owner before sampling or rely on the TCEQ warrant to enter the site..

STEP 5. DEVELOP A DECISION RULE SPECIFY THE PARAMETER THAT CHARACTERIZES THE POPULATION OF INTEREST.

TCL VOCs, SVOCs, Pesticides, PCBs, TAL total metals/mercury and cyanide, TPH and flashpoint within the containers and surface soils at the site.

SPECIFY THE ACTION LEVEL FOR THE DECISION.

Contaminants present in the samples of surface soil and containers exceed the CRQL and CRDLs or the TRRP Tier 1 Commercial/Industrial Soil PCLs.

DEVELOP A DECISION RULE. If CERCLA hazardous substances are present at concentrations greater than their CRQLs or CRDLs in the surface soil and container samples collected at the site, a CERCLA Removal action may occur.

STEP 6. SPECIFY THE LIMITS ON DECISION ERRORS DETERMINE THE POSSIBLE RANGE OF THE PARAMETER OF INTEREST.

Concentrations may range from less than CRQLs and CRDLs to greater than 10,000 ppm.

DEFINE BOTH TYPES OF DECISION ERRORS AND IDENTIFY THE POTENTIAL CONSEQUENCES OF EACH.

1. Deciding that the concentrations are below the CRQLs/CRDLS when they are actually greater. 2. Deciding that the concentrations are above the CRQLs/CRDLs when they are actually lower.

ESTABLISH THE TRUE STATE OF NATURE FOR EACH DECISION RULE.

1. Concentrations are greater than the CRQLs/CRDLs 2. Concentration are less than CRQLs/CRDLS

DEFINE THE TRUE STATE OF NATURE FOR THE MORE SEVERE DECISION ERROR AS THE BASELINE CONDITION OR THE NULL HYPOTHESIS (Ho), AND DEFINE THE TRUE STATE FOR THE LESS SEVERE DECISION ERROR AS THE ALTERNATIVE HYPOTHESIS (Ha).

The more severe decision error is to decide that the concentrations are below the CRQLs/CRDLs when they are actually above criteria, Ho – Null hypothesis. Alternate hypothesis – H1 – concentrations are above CRQLs/CRDLs when they are actually below criteria.

ASSIGN THE TERMS “FALSE POSITIVE” AND “FALSE NEGATIVE” TO THE PROPER

Ho = false negative H1 = false positive

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Ector Drum Site DECISION ERRORS. ASSIGN THE PROBABILITY VALUES TO POINTS ABOVE AND BELOW THE ACTION LEVEL THAT REFLECT THE ACCEPTABLE PROBABILITY FOR THE OCCURENCES OF DECISION ERRORS.

Probability values not assigned at this time.

STEP 7. OPTIMIZE THE DESIGN REVIEW THE DQOs. DEVELOP GENERAL SAMPLING AND ANALYSIS DESIGN. The QASP that these DQOs are attached to reflect the sample and analysis design to meet these objectives.

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APPENDICES

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Appendix A

TCEQ Investigation Report

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COMP_ECTOR_CO_20140725_COMPLAINT

Texas Commission on Environmental Quality Investigation Report The TCEQ is committed to accessibility. If you need assistance in accessing this document, please contact [email protected]

Customer: Generic Incident Principal Customer Number: CN602295370

Regulated Entity Name: ECTOR DRUM

Regulated Entity Number: RN102263472

Investigation # 1186740 Incident Numbers 200089

Investigator: TRENT MARTIN Site Classification CONDITIONALLY EXEMPT

SMALL QUANTITY GENERATOR Conducted: 07/25/2014 -- 07/25/2014 No Industry Code Assigned Program(s): INDUSTRIAL AND HAZARDOUS WASTE

Investigation Type: Compliance Investigation Location: --- 2504 MARCO DR, ODESSA, TX, 79765

---

Additional ID(s):52177

Address: 2504 N MARCO AVE, Local Unit: REGION 07 - MIDLAND ODESSA, TX , 79762 Activity Type(s): IHWCMPL - Complaint investigation

Principal(s):

Role Name

RESPONDENT GENERIC INCIDENT PRINCIPAL RESPONDENT UNITED FUEL & ENERGY CORPORATION

Contact(s): Role Title Name Phone

Regulated Entity ENVIRONMENTAL MR RANDY BEARD (432) 556-3939

Contact MANAGER Other Staff Member(s):

Role Name

Investigator RALPH JOHNSON

Supervisor WILLIAM EDMISTON

QA Reviewer RALPH JOHNSON

Associated Check List

Checklist Name Unit Name IHW COMPLAINT Ector Drum

Investigation Comments: INTRODUCTION On July 25, 2014, Environmental Investigators Ralph Johnson and Trent Martin with the Texas Commission on Environmental Quality (TCEQ) Region 7 - Midland office, conducted a complaint investigation at Ector Drum, Inc. for the potential discharge of contaminated storm water coming from the site. In accordance with TCEQ

000032

policy, the investigation was conducted unannounced. The site is located on 2604 N Marco Ave Odessa, Texas. BACKGROUND On June 23, 2014, the TCEQ Region 7 Office, received information alleging that the alleged site had potential discharge of contaminated storm water coming from the site. The Region 7 office was requested to conduct an on-site investigation to investigate the complaint. The complaint incident, #200089 was assigned to Investigator Trent Martin for investigation. GENERAL FACILITY AND PROCESS INFORMATION The site is located at 2604 N. Marco Ave. in Odessa, Texas and is operated by Ector Drum owner Mr. Randy Beard. The facility is a drum reconditioning business that is no longer in operation. The tract of land is in an industrial area but has residential areas close to the facility. SUMMARY OF ON SITE INVESTIGATION On July 25, 2014, Mr. Martin along with Senior Investigator Mr. Ralph Johnson arrived at the alleged source located 2604 N Marco Ave in Odessa, Texas and proceeded to look into the facility. The investigators were joined by Mr. Ricky George, Ector County Environmental Police. Going around the facility, it was noted that there were numerous openings throughout the fence line. Mr. Martin, Mr. Johnson, and Mr. George entered the facility through one of the broken fence panels and walked through the facility. Upon entering the operating area it was discovered that there were many 350 gallon tote-containers and 55 gallons drums that were noted to be full of unknown chemical. Also, the ground surface at various locations showed evidence of chemical contamination most likely from long-term drum storage. Underneath the loading rack nearby observed a 20'X10'X4"pool of an oily brown liquid. The facility waste storage tanks (Fac.001 and 002) are 200 bbl. tank and a 160 bbl. tank respectively. The concrete secondary containment vault was full of a mixture of water and unknown chemical. The freeboard was estimated to be approximately six to eight inches. The investigators continued to walk the entire property and discovered many more 350 gallon tote-containers and 55 gallons drums as well as a good amount of contamination on the ground. Other chemicals that were also used on-site at time of operations were discovered to still be in the facility. At the back ends of the facility, many 55 gallon drums were sealed and were found to be fool of unknown chemicals. Upon completion of the walk through of the facility, it was noticed that many of the original equipment that was at the facility was no longer there, but now housed many of the totes and drums for the facility.

SUMMARY OF EXIT INTERVIEW CONFERENCE Due to the excess amounts of waste that was left on-site, an enforcement action will be pursued citing 30 TAC 335.4 for the large amount of waste stored on-site that may contribute to the discharge of industrial waste from the site during rainfall events and endanger public health and the environment. Mr. Beards was notified by phone about the Enforcement Action. ADDITIONAL INFORMATION Due to the threat posed by the existing site conditions, Critical Infrastructure Division was contacted about the location. State contractor, SWS Environmental was subsequently notified for their response to assess site conditions. Upon reaching an agreement, SWS will secure the site, conduct random sampling of the drums and totes, overpack leaking containers, and remove wastes accumulated in the secondary containment structure. CONCLUSION The investigation on July 25, 2014, determined that the site was in violation of 30 TAC 335.4 for the large amount of waste that was discovered at the site that could cause the discharge of industrial waste in the area and endanger public health and welfare. Based on the findings of this investigation, a Notice of Enforcement will be sent to Mr. Randy Beard.

000033

NOE Date: 8/20/2014 OUTSTANDING ALLEGED VIOLATION(S) ASSOCIATED TO A NOTICE OF ENFORCEMENT

Track Number: 545847 Compliance Due Date: 02/16/2014 Violation Start Date: Unknown 30 TAC Chapter 335.4

Alleged Violation:

Investigation: 1186740 Comment Date: 08/18/2014

Failure of the company to dispose of the excessive amount of industrial waste that was collected and stored

on-site, that could be discharged into the surrounding areas, cause a nuisance for the surrounding area, and cause the endangerment to the public health and welfare.

Recommended Corrective Action: Remove all waste that was left on site. Begin the remediation process of removing all contaminated land and correcting the damages.

Signed Date ___________

____________________________________ Environmental Investigator

Signed Date ___________ ____________________________________ Supervisor

Attachments: (in order of final report submittal) _X__Enforcement Action Request (EAR) _X__Maps, Plans, Sketches _X__Letter to Facility (specify type) : NOE _X__Photographs Investigation Report ___Correspondence from the facility ___Sample Analysis Results ___Other (specify) : ___Manifests _______________________________ ___Notice of Registration _______________________________

000034



Appendix B

Drinking Water Survey Report and Water Well Inventory

000035

s

DRINKING WATER SURVEY REPORT AND

WATER WELL INVENTORY

Lonestar Drum Facility

2604 North Marco Avenue Odessa (Ector County), Texas 79762

October 28, 2014

Prepared f or:

Texas Commission on Environmental Quality Petroleum Storage Tank Division State Lead Remediation Section

P.O. Box 13087, MC-136 Austin, Texas 78711-3087

Prepared by: SWS Environment 9204 Hwy 287 NW

Fort Worth_, Texas 76131

SWS Project No. RW2-410-1411

ENVIRONMENTAL SERVICES ______________ _____,

000036

October 2 MC-137 Omar VaEMERGETEXAS CP.O. BOXAUSTIN RE: D

(E Dear Mr. On OctoQuality (Section 22604 NorThis worand was coordinatSWS on Separatedactivitiessurface wbags of rainfall erepresentimmediatwater weBanks re13, 2014visual suthese sursurvey isupply) (See Figuby SWS 2). Groundw On Octobwell. Prio

28, 2014

aldez ENCY RESCOMMISSIX 13087

N, TEXAS 7

Drinking WaEctor Count

. Valdez:

ber 8, 2014(“TCEQ”) to26.408 coverrth Marco Ark was condu

authorized tor (Mr. AnOctober 8,

d Hydrocarbs,, the oil apwater runoffconcrete to events. Fotatives of thtely authoriz

ell records seeport is inclu and SWS p

urvey and a rveys are shindicated thwere identiure 2.0 andrevealed a

water Conta

ber 8, 2014 or to sampli

24‐H

Emergenc

Remediati

Field Servi

Waste Ser

PONSE COION ON EN

78711-3087

ater Survey, ty) Texas, SW

4, SWS receo conduct a ring a 0.5-m

Avenue in Oducted under under a Wo

nthony Buck2014 during

bons (PSH) pparently ranf impacted b

build a berllowing thehe impact tzed SWS to earch from Buded as Attacpersonnel mo

0.25-mile rhown in Attahat 73 wateified by Ban

d Banks Reptotal of 50 w

amination

SWS mobiling the well,

Hour Emergenc

y Response

ion

ices

rvices

ORDINATONVIRONMEN

Former LoWS Job # R

eived a requDrinking W

mile radius ardessa, EctorSWS’s TCEork Order is

k). The worg sampling oin the wellb

n into the wby releases rm around te discovery to this wellconduct a w

Banks Envirchment 3 ofobilized to tradius door tachments 1, er wells (dnks Enviroport – Attacwells within

lized to the , an interface

cy Response @

OR NTAL QUA

onestar DrumW2-410-141

uest from theWater Survey

round the For County, TeEQ Regional ssued by therk order wasof the onsitebore. Based

well casing thof oil from the well to of the PSH

l. The TCwater well suonmental Da

f this report. he site on Oto door wal2 and 3 of

omestic, irrnmental Dachment 3.0)n a 0.25 rad

site to collee probe was

877.742.4215

ALITY

m Facility, 11

e Texas Coy in accordaormer Lone

exas (See Att Umbrella Ee TCEQ Ems authorizede well of apd on observahrough an edrums at thprevent add

H, SWS coCEQ Centralurvey and SWata (“Banks” Banks’ rep

October 13, 2lking water f this report.rigation, inata in use w). The door

dius of the s

ect a water ss used to gau

5

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2604 North

ommission oance with Testar Drum F

ttachment 1-Emergency Rmergency Red following pproximatelyations made

electric condhe site.-SWSditional impntacted andl Office TCWS ordered ”) out of Auport was rece2014 to condwell survey

. The resulndustrial anwithin 0.5 mr to door suite (See Tab

sample fromuge the well

9204 Hwy 2Fort Worth, TXPhone: 817.84

Fax: 817.30w.swsenvironmen

h Marco Ave

on Environmexas Water

Facility locatFigures 1 an

Response conesponse Prothe discover

y 1.8 ft. of Pe during the duit as a resuS personnel pacts from fd notified TCEQ coordia 0.5-mile r

ustin, Texas.eived on Ocduct the 500

y. The results of the Bnd public wmiles of theurvey conduble 1 and Fi

m the onsite wl for the pres

287 NWX 7613147.133306.8086ntal.com

enue,

mental Code ted at nd 2). ntract

ogram ry by Phase

field ult of used

future TCEQ inator radius The

ctober 0-foot lts of

Banks water e site. ucted igure

water sence

000037

of Phase bore at anon-aqueDallas, T6010), vo(TX Met An evaluarsenic (2mg/L), aConcentrchromiumGroundwrespectivlimits forTRRP TiVOCs orsamples wat a conclimit at 1I ResidenTPH resumg/kg anindicatedlimits, Cand C21C12-C16mg/L. FodetectioncomparisC21 and respectivincluded Public W FollowinAdministsupply avavailabiliservice. the subjelocated oDrive is

Separated Ha depth of 2eous and aqTexas. Theolatile and shods 1005 a

uation of the2.46 mg/L),

and zinc (274ration Levelm (0.298 m

water Protectvely. It shour all of the oier I Resider SVOCs wewere requirecentration b.00 mg/L. T

ntial Groundults indicatend for the wd aliphatic h8-C10 (0.30-C35 (264 m

6 fraction esor the aromn limits, C12son with the

C21-C36 cvely. A copy

as attachme

Water Suppl

ng the site intration Officvailability foity based onThese inclu

ect property on North Macurrently in

24‐H

Emergenc

Remediati

Field Servi

Waste Ser

Hydrocarbon27.45 feet bequeous phase samples wsemi-volatile

and 1006).

e laboratory chromium (4 mg/L) all s (PCLs). Fmg/L), and tive Concentuld be noted other non-deential Grounere detected ed to be ran elow the quThis concentdwater PCL d elevated to

water phase hydrocarbon0 mg/L), C1mg/L) exceestablished at

matic hydroc2-C16 (0.39

e TRRP Tiercarbon rangey of the signeent 4.0 of thi

ly Availabil

spection, SWce (Mr. Agafor the area. n conversatiode the new hand the Cit

arco and on n the proces

Hour Emergenc

y Response

ion

ices

rvices

ns (PSH). Apelow grounde liquids an

were analyzee organic co

analytical r33.1 mg/L),exceeded th

For the watezinc (7.41

tration Levehowever, th

etected priorindwater Prot

but the deteat (1000 x).

uantitation litration, althoof 0.005 mgotal petroleu(274 mg/L)

ns in the C610-C12 (210eding the TRt 2.4 mg/L arbons, the

90 mg/L), Cr I Residenties exceed thed laboratorys report.

ity

WS personneapita Bernal Eighteen o

on with Mr.housing devty of OdessUS Busine

s of convert

cy Response @

pproximatelyd surface. SWnd submittedd for conceompounds (E

results for th copper (5.0he TRRP Tier phase, con mg/L) ex

els (PCLs) ohat because oity pollutanttective Concection limits A benzeneimit (J Flagough estimatg/L establishum hydrocar). The spec6-C8 carbon0 mg/L). C1RRP Tier I and for thelaboratory

C16-C21 (4.7ial Groundwhe criteria ofy report and

el contacted l, Ph. No 43of the thirty- Bernal althelopments loa Country Css 20. The ting over to

877.742.4215

y 1.8 feet of WS personnd the sampleentrations ofEPA Metho

he oil phase00 mg/L), leier I Residenncentrations xceeded theof 0.002 mg/of the naturet metals (exccentration Le were so ele

e concentratigged) but abted, is substahed for this rbons (TPH)ciation of then range bel2-16 (4.61 mResidential

e C21-C-C3reported C-73 mg/L) an

water PCLs if 0.98 mg/L

d completed c

personnel w32-335-3210-five facilitiehough only aocated northClub as welNew Life C City water

5

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f oil was meanel collectedes to Xencof total meta

od 8260 and

e indicated cead (3.34mg/ntial Groundof mercury

e TRRP Ti/L), 0.10 mge of the matcept for silveevels (PCLsevated due toion (2.90 mg

bove the labantially abovcompound. ) for the oil e TPH by Tow the labomg/L), C16-l Groundwa

35 fraction e-7-C12 belownd C21-C36indicated the

L, 0.73 mg/Lchain of cus

with the City 0) to verify es surveyeda few have chwest, north,l as a few o

Church locatand will us



asured in thed a sample oo Laboratorials (EPA Med 8270) and

concentratio/L), nickel (dwater Prote(0.00211 m

er I Resideg/L and 7.3 mtrix, the deteer) are abovs). Similarlo the dilutiog/L) was reporatory deteve the TRRP The Texas phase at 533

TX Method oratory dete-C21 (15.3 mter PCLs foestablished w the labor

6 (17.3 mg/Le C12-C16, L and 0.73 mtody docum

of Odessa Wthe public w

d have City wconnected to, and northeaof the businted at 7184 se their well

287 NWX 7613147.133306.8086ntal.com

e well of the ies of ethod TPH

ons of ( 2.92 ective

mg/L), ential mg/L

ection ve the ly, no on the ported ection P Tier 1005 3,000 1006

ection mg/L) or the at 39 ratory L). A C16-mg/L

ment is

Water water water o this ast of

nesses Club

ls for

000038

irrigationincludingresidents During thwater mewithin a The survresidentiaare provi The survMr. Tom 0.5-Mile The BanirrigationThe Banlocated athis site. supply thcurrentlyChurch imeter waHomes aSuperinteall the reOdessa Csolely forwater supthe wellsused for 500-Foot A visual release smiles of results owells witmost of tfor washhowever

n purposes g, O.H. Ivie, within the C

he field inspeters at all su0.25 radius

vey area is al area is locided with wa

vey area has m Kerr as the

Water Wel

ks 0.5-mile n, industrial nks report idat 7184 Club

The facilithe onsite poy connected is in the proas observed

are being useendent). Allesidences inCountry Clubr irrigation ppply. Similas identified birrigation pu

t Visual Sur

walking doite in all dirthe release f the field sthin 0.25 mithe wells arehing hands a

had ice ma

24‐H

Emergenc

Remediati

Field Servi

Waste Ser

only. The , Lake SpenCity limits.

pection, condurveyed locaof the subjecmade up p

cated northwater from the

recently beedirector (Ph

ll Records S

Water Welland public w

dentified fou Drive. The ty was onceol. Bottled to the wate

ocess of conat the site

ed only for irl the new ho

nspected durb indicated tpurposes andarly, based oby Banks at urposes and C

rvey and 0.2

oor-to-door wrections. A site and the survey and wle radius of e not used foat sinks andachines conn

Hour Emergenc

y Response

ion

ices

rvices

City of Odce, and Tho

ducted as paations as a fuct site. City

primarily of west north ane City of Ode

en added as h. 432-335-4

Search

l ReportTM (water supplyur (4) publicfield survey

e part of thewater for d

er wells onsverting entirduring the

rrigation puromes are proring the fieldthat all the wd the Club Hon communiSunset MemCity water is

25-Mile Wa

water well swalking anddoor to doo

water well ithe subject sor drinking wd for water fnected to th

cy Response @

dessa obtainmas and som

art of this suurther indicaty water meter

residential nd northeast essa.

part of the 4634).

(Attachmenty) were idenc water suppy however ine City of Oddrinking watesite. Accorrely to City field survey

rposes accorovided City wd survey. Cwells depicte

House is provication with morial Gardes provided fo

alking Wate

survey was d driving suor survey reinventory resite. Based owater purposfor toilets a

he water sup

877.742.4215

ns water frome water we

urvey, attemtion of the urs were obseand mixed

t of the subje

Groundwate

t 3) indicatentified in useply wells opndicated that dessa Countrer is providerding to Mr

water and y. The watrding to Mr. water and w

Communicatied in Banks vided water the funeral

ens located aor domestic

r Well Surv

performed wurvey was coesults are sumevealed the on interviewses but are m

and irrigationpplied from

5

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om surface ells provide

mpts were mause of the puerved at only

d commerciaect site and a

er Conservat

ed 73 water e within 0.5 perated by N

only two wetry Club anded although r. Tim Halsta newly inster wells owScott Cook

water meters ion with theReport (7 wby the City director (Mr

at 6801 Eastuse.

vey

within at leaonducted wimmarized inpresence of

ws with the wmainly used n purposes. their onsite



water reserwater for u

ade to locateublic water suy a few locatal propertiesall the reside

tion District

wells (dommiles of the

New Life Chells are locatd the water

the ice maktead (Pastortalled City w

wned by Per(Permian Hwere observ

e manager owells) are utiof Odessa Pr. Mel Widet Business 20

ast 500 ft. oithin at leastn Table 1.0. f fifty (50) wwell owners/

to provide w Three faci

e wells inclu

287 NWX 7613147.133306.8086ntal.com

rvoirs se by

e city upply tions. s. A ences

t with

mestic, e site. hurch ted at wells ker is r) the water rmian

Homes ved at of the ilized

Public eman) 0, are

of the t 0.25 The

water /users water ilities uding

000039

'f"e• c Re

Re.,, t ori

I' C :l 5£!"\r Ct'S

.v

12Qa 287 \ For. Wort x 71':131 P'lo~e 817 847 1333

Schoppa's Material Handling located at 2627 North Marco Ave., Permian Anchors located at 6927 East Business 20, and New Life Church located at 7184 Club Drive. The usage of water from wells at six (6) facilities was not documented as no one was available to interview. These facilities include: 1) H.K. Electric located at 2701 North Marco A venue, 2) Mr. Bobby Moore-6938 East Commerce Street, 3) B- Mac Corporation, 6955 East Commerce Street. 4) Adam Doy]e-6958 East Commerce Street, 5) PRB Machine -6968 East Commerce Street and 6) APP Auto Pax/Cardinal Industries Inc. located at 6977 East Commerce Street ·

We appreciate the opportunity to assist you with this project and to provide you with this infonnation. If you have any questions. please call me at 817 829-9135.

Si, Damon~~ Senior Geologist

Attachments: Figure 1.0 Site Vicinity Map, Figure 2.0 Aerial Photograph, Table 1.0 Survey Data, BanJcs 0.5-Mile Radius Water Well Report, Access Agreements, Analytical Data

2'1 Hour Emergency Response (!iJ 877 742 4215

000040

24‐H

Emergenc

Remediati

Field Servi

Waste Ser

Wa

Hour Emergenc

y Response

ion

ices

rvices

ATTA

Vicinity

ater Well Lo

cy Response @

ACHMENT

y Map - Figu

ocation Map

877.742.4215

T 1

ure 1

p - Figure 2

5

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000041

9204�Hwy�287�NWFort�Worth,�Texas�76131

Site�Location

000042

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Date:�10/14/14

Project�No.RW2�410�1411

Figure�3.00.25�Mile�Radius�Aerial�Map

2604�N.�Marco�Ave.Odessa,�Texas�79762

N

12 11

10

9

9 9

12

13

2122 23 24

25

26 28

27 30

2931

34

32 3335

18

20

9

199

1

17

16

16

9

15

45

5

7

8

32

14

7

000043

24‐H

Emergenc

Remediati

Field Servi

Waste Ser

Hour Emergenc

y Response

ion

ices

rvices

ATTA

Table 1

cy Response @

ACHMENT

1 – Survey D

877.742.4215

T 2

Data

5

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287 NWX 7613147.133306.8086ntal.com

000044

Table 1Properties Surveyed Within 0.25 Mile of

2604 N. Marco Ave.Odessa, Texas 79762

SWS Figure 1.0 Map ID No.

Banks Env.Well No.

State Well ID No.

Distance from known extent of groundwater impact contamination

(feet)

Physical Address of Well

Latitude Longitude(Decimal Degrees)

Well No.Total Depth

(feet)Screened Interval

(feet)Sealed Interval

(feet)

Private Drinking Water Well? (Yes

or No)

Affected or Potentially

Affected? (Yes or No)

Property Name, Current Mailing Address

Well Users Name, Current Mailing Address

1 Not Identified NA Subject Site31.88548 Lat.

-102.29437 Long.1 well UNK UNK UNK

Well formerly used as PW, well at

store not in useYes -1.5 ft. PSH Former Lonestar Drum Recycling Ronny Beard

2 Not Identified NA 293' and 764'

31.88548 Lat. -102.29349 Long./

31.887923 Lat. -102.295131 Long

2 Wells-1 at each location

UNK UNK UNKWells used for toilets/washing

hands

Not at present time*

Guardian Wellhead Protection, 2584 North Marco and 6907 E.

Commerce, Odessa 79762

C/O Lance Bolds- Attorney 11757 Katy Freeway, Houston Texas 77079

3 3 & 445-06-8NN WIID3137

350' and 334'

31.885157 Lat. -102.293884 Long./

31.884999 Lat. -102.29361 Long.

2 Wells Adjacent

110' 120'

80-110' 60-120'

0-20' 0-60'

Stephenson well used for toilets

UNK Former Foster Storage*Randy Stephenson

2564 North Marco Ave., Odessa, TX 79762

4 Not Identified NA NA NA NA NA NA NA City Water NA Woody Gregory2414 North Marco Ave.,

Odessa, TX 79762

5 Not Identified45-0-08

2 others not idenitified

443', 875'm 834'

31.884842 Lat. -102.293566 Long./

31.883519 Lat. -102.293838 Long./

31.883667 Lat. -102.293662 Long.

3 Wells have City Water

112' UNK UNK

71-112 UNK UNK

UNK UNK UNK

No, used for irrigation

UNK

Scott Thane Ditching Service LTD 6901 E. Business 20 Odessa, TX 79768

*Scott Thane P.O. Box 13888,

Odessa, TX 79762

6 Not Identified NA 813'31.883796 N Lat

-102.293515 W Long.1 well UNK UNK UNK

Yes, use well for ice maker

UNKPermian Anchors 6927 E. Business

20 Odessa, TX 79762

*Sylvia Herriage 6927 E. Business 20 Odessa, TX 79762

7 Not Identified NA 797'31.883923 Lat.

-102.293182 Long.1 well UNK UNK UNK

Well used for toilets ect.

UNKSatellite Distributors 6931 E. Business 20 Odessa, TX 79762

Satellite Distributors 6931 E. Business 20 Odessa, TX 79762

8Banks 7 & 13

MisplottedNA 628'

31.884645 Lat. -102.293072 Long.

1 well for irrigation UNK UNK UNK City Water UNKGraham Brothers Entertainment

6999 E. Business 20 Odessa, TX 79762

Graham Brothers Entertainment 6999 E. Business 20 Odessa, TX 79762

9 8 Misplotted NA 1035', 1268', 831'

31.885861 Lat. -102.291020 Long./

31.887549 Lat. -102.290801 Long./

31.886282 Lat. -102.291723 Long.

3 wellsUNK UNK UNK

UNK UNK UNK

UNK UNK UNK

Bottled drinking water/toilets, ect.

UNKRama Fabricators

P.O. Box 7346 Odessa, Texas 79760-7346

*Ronny Rains/Rama Fabricators P.O. Box 7346

Odessa, Texas 79760-7346

9 Not Identified NA 597'

31.88432 N Lat. -102.294994 Long.

1 well UNK UNK UNKBottled

water/irrigation, toilets

UNKRama Fabricators




000045




Banks Env.Well No.

State Well ID No.


(feet)



Well No.Total Depth



(feet)


or No)






31.886961 Lat. -102.294991 Long.

1 well UNK UNK UNKBottled

water/irrigation, toilets

UNKRama Fabricators




1027, 31, 34, 39,

42See Banks Report 1641', 1774'

31.886872 Lat. -102.289180 Long./

31.887266 Lat. -102.288849 Long

2 wells identifiedSee Banks

ReportSee Banks

ReportSee Banks

ReportYes, ice maker,

poolUNK

New Life Church 7184 Club Drive

Odessa, TX 79762

*Tim Halstead, Pastor 7184 Club Drive

Odessa, TX 79762

117, 15, 17, 22,

23, 28, 31See Banks Report Various See Banks Report 7+

See Banks Report

See Banks Report

See Banks Report

No-Club house on City Water

UNKOdessa Country Club No. 1 Fairway Drive Odessa, TX 79765

Ryan George, Club Manager No. 1 Fairway Drive Odessa, TX 79765

1218, 19, 24, 25,


See Banks Report

See Banks Report

See Banks Report

City Water wells for irrigation

UNKPermian Homes LLC

13020 Hwy 191 Odessa, TX 79707

David Cook, President 13020 Hwy 191

Odessa, TX 79707

139, 12, 13, 16,


See Banks Report

See Banks Report

See Banks Report

City Water wells for irrigation

UNKSunset Memorial Gardens

6801 E. Business 20 Odessa, TX 79762

Mel Wideman, Funeral Director 6801 E. Business 20 Odessa, TX 79762

14 14 45-06-8NN 1058'

31.883124 Lat. -102.294799 Long.

1 well 113' 50-113' 48-50'Water used for toilets, sinks

UNKEwing Golf & Irrigation

6895 E. Business Hwy 20 Odessa, TX 79762

Tyler Mayes, Manager 6895 E. Business Hwy 20

Odessa, TX 79762


31.883213 Lat. -102.294822 Long.

1 well UNK UNK UNKWater used for toilets, sinks

UNKMidland-Odessa Auto Auction

2521 N. Marco Ave. Odessa, TX 79762

Kye Johnson, Owner 2521 N. Marco Ave. Odessa, TX 79762

16 1 idenitified, 6 45-06-8558' 524'

31.884912 Lat.

-102.295492 Long./ 31.884727 Lat.

-102.295362 Long.

2 wells107' UNK

50-107' UNK

0-15' UNK

Water used for irrigation, toilets,

sinksUNK

*Tommy and Brianne Hudson 2565 N. Marco Ave. Odessa, TX 79762

*Tommy and Brianne Hudson 2565 N. Marco Ave. Odessa, TX 79762

17 2 45-06-8NN 336'

31.886031 Lat. -102.295236 Long.

1 well 110' Not on log 0-30'well used for toilets, sinks

UNKEnergy Coil & Riggin 2925 N. Marco Ave.

Midland, Texas 79762

Energy Coil & Riggin 2925 N. Marco Ave.

Midland, Texas 79762

18 Not Identified NA451' 485'

31.886259 Lat.

-102.295967 Long./ 31.886888 Lat.

-102.295957 Long.

2 wells UNK UNK

UNK UNK

UNK UNK

Well used for RO ice maker

UNKShoppas Material Handling


Leroy Bird, Manager 2627 N. Marco Ave. Odessa, TX 79762


31.886678 Lat. -102.294949 Long.

1 well UNK UNK UNKWater used in toilets, sinks

UNKVital Signs


*Chris Byrne, Owner 2628 N. Marco Ave. Odessa, TX 79762

000046




Banks Env.Well No.

State Well ID No.


(feet)



Well No.Total Depth



(feet)


or No)





20 5 45-14-1 418'

31.887095 Lat. -102.29460 Long.

1 well 92' 70-80' 0-59'Water used in toilets, sinks

UNKSabre Energy Services


David Collyer, Manager 264 N. Marco Ave. Odessa, TX 79762


31.887685 Lat. -102.295881 Long.

1 well UNK UNK UNKUNK, no one

availableUNK

H K Electric 2701 N. Marco Ave. Odessa, TX 79762

H K Electric 2701 N. Marco Ave. Odessa, TX 79762

22 Not Identified NA 293' and 764'

31.88548 Lat. -102.29349 Long./

31.887923 Lat. -102.295131 Long

2 Wells-1 at each location

UNK UNK UNKWell used for

toilets/washing hands

Not at present time*

Guardian Wellhead Protection, 2584 North Marco and 6907 E.

Commerce, Odessa 79762

C/O Lance Bolds- Attorney 11757 Katy Freeway, Houston Texas 77079

2310 10

WIID 13903 2

759'

31.888055 Lat. -102.294721 Long.

1 well 117' 67-117'50-67' 0-10'

Well used for toilets, sinks

UNK

Davis Lynch/Forum Energy Technologies

6919 East Commerce Odessa, TX 79762

*Kashie Kazanii 6919 East Commerce

Odessa, TX 79762


31.888052 Lat. -102.294712 Long.

1 well UNK UNK UNKWell used for toilets, sinks

UNKIron Horse Tods LLC 6923 East Commerce

Odessa, TX 79762

Michelle Ozuna, Manager 6923 East Commerce

Odessa, TX 79762


31.888185 Lat. -102.294082 Long.

1 well UNK UNK UNKwell used for toilets, sinks

UNKSecorp Industries


Chris Barber 6937 East Commerce

Odessa, TX 79762


31.887104 Lat. -102.293753 Long.

1 well UNK UNK UNK UNK UNKBobby Moore


Bobby Moore 6938 East Commerce

Odessa, TX 79762


31.888234 Lat. -102.292937 Long.


UNKCounty Line Adult Superstore

6947 E. Commerce Odessa, TX 79762

Nick Menke, Manager 6947 E. Commerce Odessa, TX 79762


31.887176 Lat. -102.293390 Long.


UNKCTI


Jim Cameron, Owner 6926 East Commerce

Odessa, TX 79762


31.887050 Lat. -102.293037 Long.


UNKRicky New


Ricky New 6948 East Commerce

Odessa, TX 79762


31.888205 Lat. -102.293358 Long.

1 well UNK UNK UNK UNK UNKB-Mac Corp.


B-Mac Corp. 6955 East Commerce

Odessa, TX 79762

000047




Banks Env.Well No.

State Well ID No.


(feet)



Well No.Total Depth



(feet)


or No)





31 8 WIID35975 576'

31.886944 Lat. -102.292777 Long.

1 well 120' 10-120' 0-20' UNK UNKAdam Doyle


Adam Doyle 6958 East Commerce

Odessa, TX 79762


31.888235 Lat. -102.293017 Long.


UNKSystech


*Larry Thorton 6965 East Commerce

Odessa, TX 79762


31.888617 Lat. -102.292449 Long.


UNKPro Inspection Inc.


David Nance, Owner 6975 East Commerce

Odessa, TX 79762


31.886938 Lat. -102.292568 Long.

1 well UNK UNK UNK Unknown use UNKPRB Machine


PRB Machine 6968 East Commerce

Odessa, TX 79762


31.888695 Lat. -102.291982 Long.

1 well UNK UNK UNK Unknown use UNK

APP Auto Pax/ Cardinal Industries Inc. 6977 East Commerce

Odessa, TX 79762

APP Auto Pax/ Cardinal Industries Inc. 6977 East Commerce

Odessa, TX 79762

000048

24‐H

Emergenc

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Field Servi

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Hour Emergenc

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287 NWX 7613147.133306.8086ntal.com

000049

Water Well Report

Water WellReport

Lone Star Drum Facility

2604 N. Marco Ave

Odessa, TX

PO #: FW3-408-1470

ES-112845

Friday, October 10, 2014

Prepared for:

SWS ENVIRONMENTAL SERVICES-FORT WORTHPO BOX 18619Panama City Beach, FL 32417

WW_ES-112845_de3d1387.pdf

Banks Environmental Data, Inc. - 1601 Rio Grande, Ste. 500 - Austin, TX 78701 - 800.531.5255 P - 512.478.1433 Fwww.banksenvdata.com

000050

Geographic Summary 3

Maps

Summary Map - 0.5 Mile Radius 4

Topographic Overlay Map - 0.5 Mile Radius 5

Current Imagery Overlay Map - 0.5 Mile Radius 6

Water Well Details 7

Database Definitions and Sources 157

Disclaimer 158

Water Well Report

Table of Contents Lone Star Drum Facility

Page 2Banks Environmental Data, Inc. - 1601 Rio Grande, Ste. 500 - Austin, TX 78701 - 800.531.5255 P - 512.478.1433 F

www.banksenvdata.com

000051

Location

TX

Coordinates

Longitude & Latitude in Degrees Minutes Seconds -102° 17' 40", 31° 53' 9"

Longitude & Latitude in Decimal Degrees -102.294372°, 31.88596°

X and Y in UTM 755919.18, 3530988.64 (Zone 13)

Elevation

Target Property lies 2883.07 feet above sea level.

Zip Codes Searched

Search Distance Zip Codes (historical zip codes included)

Target Property 79762

0.5 miles 79762, 79765

Topos Searched

Search Distance Topo Name

Target Property Odessa NE (1982)

0.5 miles Odessa NE (1982)

Water Well Report

Geographic Summary Lone Star Drum Facility



000052


Well

Well Cluster

Target Property

Search Buffer

Texas Quad Index

0' 500' 1000'

1 : 9,0001 inch = 0.142 miles

1 inch = 750 feet1 centimeter = 0.090 kilometers

1 centimeter = 90 meters

Lambert Conformal Conic Projection1983 North American Datum

First Standard Parallel: 33 0' 00" NorthSecond Standard Parallel: 45 0' 00" North

Central Meridian: 96 0' 00" WestLatitude of Origin: 39 0' 00" North

Water Well Report

Summary Map - 0.5 Mile Radius



000053


Well

Well Cluster

Target Property

Search Buffer

Target Property Quad Name(s)Odessa NE (1982)

0' 500' 1000'

1 : 9,0001 inch = 0.142 miles

1 inch = 750 feet




Water Well Report

Topographic Overlay Map - 0.5 Mile Radius



000054


Well

Well Cluster

Target Property

Search Buffer

0' 500' 1000'

1 : 9,0001 inch = 0.142 miles

1 inch = 750 feet1 centimeter = 0.090 kilometers

1 centimeter = 90 meters




Water Well Report

Current Imagery Overlay Map - 0.5 Mile Radius



000055

1 WIID294351 TX TWDB WIID Jamie Poldrack Domestic 120 6/30/2012 -102.293888 31.885833 2883 ft () View

2 45-06-8NN TX TCEQ HIST Berry Hill Drilling &Supply Domestic 110 05/03/1976 -102.295236 31.886031 2883 ft (+) View

3 45-06-8NN TX TCEQ HIST Ch. Foster Domestic 110 03/12/1982 -102.293884 31.885157 2883 ft () View

4 WIID311374 TX TWDB WIID Randy Stephenson Domestic 120 1/11/2013 -102.29361 31.884999 2883 ft () View

5 45-14-1 TX TCEQ HIST Petroplex Savings Industrial 92 10/03/1988 -102.294985 31.887108 2883 ft (+) View

6 45-06-8 TX TCEQ HIST Briaane Hudson Domestic 107 05/03/1995 -102.295352 31.884727 2882 ft (-1) View

7 45-06-812 TX TWDB GW Odessa Country Club Domestic 115 01/01/1946 -102.292499 31.885555 2883 ft () View

8 WIID359750 TX TWDB WIID Adam Doyal Domestic 120 4/12/2014 -102.292777 31.886944 2882 ft (-1) View

9 45-06-805 TX TWDB GW Sunset Memorial Gardens#2 well Irrigation 116 01/01/1961 -102.296666 31.885833 2883 ft () View

10 WIID139032 TX TWDB WIID Bob Simpkins Domestic 117 4/8/2008 -102.294721 31.888055 2883 ft () View

11 45-06-8 TX TCEQ HIST Watson Packers Domestic 112 07/09/1987 -102.293829 31.883726 2882 ft (-1) View

12 45-06-802 TX TWDB GW Sunset Memorial Gardens Irrigation 116 01/01/1963 -102.296944 31.886944 2883 ft (+) View

13 45-06-809 TX TWDB GW Sunset MemorialGardens, Inc. Well #14 Irrigation 120 n/a -102.296944 31.887221 2883 ft () View

14 45-06-8NN TX TCEQ HIST American Fence Domestic 113 n/a -102.294437 31.883206 2882 ft (-1) View

15 45-06-813 TX TWDB GW Odessa Country Club Irrigation 115 01/01/1946 -102.292221 31.883888 2882 ft (-1) View

16 45-06-808 TX TWDB GW Sunset Memorial Gardens Unused 102 n/a -102.295833 31.883333 2881 ft (-2) View

17 45-06-911 TX TWDB GW Odessa Country Club Irrigation 115 01/01/1938 -102.290833 31.886666 2880 ft (-3) View

18 WIID347507 TX TWDB WIID Permian Home Domestic 120 10/18/2013 -102.291944 31.888888 2877 ft (-7) View


20 WIID238794 TX TWDB WIID Interstate Treating Domestic 114 2/1/2007 -102.290277 31.887777 2876 ft (-7) View

21 45-06-9 TX TCEQ HIST Sunset Memorial Gardens Industrial 99 03/31/1988 -102.297485 31.882999 2880 ft (-3) View

22 45-06-910 TX TWDB GW Odessa Country Club Domestic 115 01/01/1938 -102.290833 31.88861 2876 ft (-7) View

23 45-14-2 TX TCEQ HIST Odessa Country Club Irrigation 114 05/27/1997 -102.289662 31.887042 2876 ft (-7) View



26 WIID347788 TX TWDB WIID Permian Homes Domestic 115 10/18/2013 -102.293055 31.890277 2876 ft (-7) View

27 G0680072A TX TCEQ PWS NEW LIFE CHURCH Public

Supply 130 n/a -102.289032 31.887068 2874 ft (-9) View

28 45-06-905 TX TWDB GW Odessa Country Club Irrigation 135 n/a -102.288888 31.886388 2876 ft (-7) View

29 45-06-804 TX TWDB GW Sunset Memorial Gardens Irrigation 116 01/01/1955 -102.299721 31.884444 2882 ft (-1) View

30 45-06-9 TX TCEQ HIST Michael McCulloch Industrial 113 01/07/2002 -102.292206 31.881444 2878 ft (-5) View


31 G0680072D TX TCEQ PWS NEW LIFE CHURCH Public

Supply 114 05/27/1997 -102.289032 31.887902 2872 ft (-11) View

32 WIID355654 TX TWDB WIID Extreme Exteriors Irrigation 115 1/28/2014 -102.289999 31.889166 2873 ft (-10) View

33 WIID304978 TX TWDB WIID Louis B. Sweeden Domestic 130 10/12/2012

34 45-06-912 TX TWDB GW New Life Church Well #1 Unused 130 n/a

34 G0680072B TX TCEQ PWS NEW LIFE CHURCH Public

Supply 130 n/a

-102.290555 31.889721 2874 ft (-9) View

-102.28861 31.886944 2873 ft (-10) View

-102.28875 31.886792 2874 ft (-9) View

35 WIID301179 TX TWDB WIID Gene Kirby Domestic 120 8/20/2012 -102.3 31.887777 2881 ft (-2) View

36 WIID115965 TX TWDB WIID Angle Development Domestic 110 5/25/2007

37 45-06-913 TX TWDB GW New Life Church Well #2 Unused 130 n/a

38 WIID141952 TX TWDB WIID Pradon Construction Domestic 110 4/16/2008

39 45-06-915 TX TWDB GW New Life Church Well #4 Unused 114 05/27/1997

-102.294721 31.89111 2878 ft (-5) View

-102.288333 31.886666 2874 ft (-10) View

-102.291388 31.881388 2877 ft (-6) View

-102.28861 31.887777 2871 ft (-12) View

39 G0680072C TX TCEQ PWS NEW LIFE CHURCH Public

Supply 112 08/21/1989 -102.28875 31.887625 2872 ft (-11) View

40 45-06-803 TX TWDB GW Sunset Memorial Gardens Irrigation 116 01/01/1968 -102.300555 31.88611 2883 ft (+) View

Water Well Report

Water Well Details Lone Star Drum Facility

Map ID Source ID Dataset Owner of Well Type ofWell

DepthDrilled

CompletionDate Longitude Latitude Elevation Driller's

Logs



000056

41 WIID318031 TX TWDB WIID Bill Satler Irrigation 85 3/22/2013 -102.3 31.88361 2881 ft (-2) View

42 45-06-914 TX TWDB GW New Life Church Well #3 Plugged orDestroyed 112 08/21/1989 -102.288333 31.887499 2870 ft (-13) View

43 45-06-8 TX TCEQ HIST Lenora Pike Domestic 110 08/26/1986 -102.300976 31.884909 2883 ft () View

44 WIID142005 TX TWDB WIID Pradon Construction Domestic 110 4/16/2008 -102.29111 31.880832 2876 ft (-7) View

45 WIID262160 TX TWDB WIID Jimmy Sanders Domestic 110 8/13/2011 -102.300555 31.888888 2881 ft (-2) View


47 45-06-8 TX TCEQ HIST Lewie Montgomery Domestic 114 09/29/1975 -102.301596 31.886762 2884 ft (+) View


49 45-06-8NN TX TCEQ HIST Jean Pike Domestic 115 09/30/1978 -102.301666 31.884726 2883 ft () View

50 WIID294305 TX TWDB WIID Rhonda Krogh Domestic 110 6/21/2012 -102.301944 31.886944 2884 ft (+1) View

51 WIID296304 TX TWDB WIID CLAY MCFADDEN Irrigation 90 8/10/2012 -102.301944 31.887221 2884 ft (+1) View

51 WIID296698 TX TWDB WIID Rick Gibson Domestic 115 7/13/2012 -102.302222 31.887221 2884 ft (+1) View

52 45-06-8 TX TCEQ HIST Julio Nunez Jr. Domestic 108 09/05/1997 -102.299653 31.881104 2877 ft (-6) View

52 45-06-8 TX TCEQ HIST Julio Nunez, Jr. Domestic 102 09/05/1997 -102.299514 31.881155 2877 ft (-6) View

53 WIID274586 TX TWDB WIID Roger Clayton Domestic 105 11/14/2011 -102.301666 31.883333 2882 ft (-1) View

53 WIID274591 TX TWDB WIID Roger Stone Domestic 110 11/14/2011 -102.301666 31.883333 2882 ft (-1) View

54 WIID294352 TX TWDB WIID Bobby Cox Properties Domestic 120 6/30/2012 -102.294444 31.892777 2879 ft (-4) View

55 WIID291297 TX TWDB WIID Bobby Cox Domestic 120 5/9/2012 -102.296666 31.892499 2882 ft (-1) View




58 WIID58154 TX TWDB WIID Darrel Farris Domestic 111 4/29/2005 -102.300555 31.890555 2884 ft (+1) View

59 WIID286184 TX TWDB WIID CORY BIZZELL Irrigation 70 4/17/2012 -102.302222 31.88361 2882 ft (-1) View

60 WIID315334 TX TWDB WIID David Johnston Irrigation 110 3/15/2013 -102.297777 31.879443 2876 ft (-7) View

61 WIID294304 TX TWDB WIID Greg Hand Domestic 110 6/21/2012 -102.302777 31.886388 2884 ft (+1) View

61 WIID302974 TX TWDB WIID DOUG MILLICAN Irrigation 104 10/24/2012 -102.302777 31.886388 2884 ft (+1) View

61 WIID302977 TX TWDB WIID JUAN VILLAREAL Irrigation 104 10/24/2012 -102.302777 31.886388 2884 ft (+1) View

62 WIID299888 TX TWDB WIID Mark Bickers Domestic 117 8/29/2012 -102.301388 31.889999 2885 ft (+2) View

Well SummaryWater Well Dataset # of WellsTX TCEQ HIST 14TX TCEQ PWS 4TX TWDB GW 18TX TWDB WIID 35

Total Count 71



Water Well Report

Water Well Details Lone Star Drum Facility

Map ID Source ID Dataset Owner of Well Type ofWell

DepthDrilled

CompletionDate Longitude Latitude Elevation Driller's

Logs

000057



Appendix C

EPA ERT SOP 2012 Soil Sampling

000058

U. S. EPA ENVIRONMENTAL RESPONSE TEAM

STANDARD OPERATING PROCEDURESSOP: 2012

PAGE: 1 of 13REV: 0.0

DATE: 02/18/00SOIL SAMPLING

CONTENTS

1.0 SCOPE AND APPLICATION

2.0 METHOD SUMMARY

3.0 SAMPLE PRESERVATION, CONTAINERS, HANDLING, AND STORAGE

4.0 POTENTIAL PROBLEMS

5.0 EQUIPMENT

6.0 REAGENTS

7.0 PROCEDURES

7.1 Preparation7.2 Sample Collection

7.2.1 Surface Soil Samples7.2.2 Sampling at Depth with Augers and Thin Wall Tube Samplers7.2.3 Sampling at Depth with a Trier7.2.4 Sampling at Depth with a Split Spoon (Barrel) Sampler7.2.5 Test Pit/Trench Excavation

8.0 CALCULATIONS

9.0 QUALITY ASSURANCE/QUALITY CONTROL

10.0 DATA VALIDATION

11.0 HEALTH AND SAFETY

12.0 REFERENCES

13.0 APPENDIX Figures

SUPERCEDES: SOP #2012; Revision 0.0; 11/16/94; U.S. EPA Contract 68-C4-0022.

000059






The purpose of this standard operating procedure (SOP) is to describe the procedures for the collection ofrepresentative soil samples. Sampling depths are assumed to be those that can be reached without the useof a drill rig, direct-push, or other mechanized equipment (except for a back-hoe). Analysis of soil samplesmay determine whether concentrations of specific pollutants exceed established action levels, or if theconcentrations of pollutants present a risk to public health, welfare, or the environment.

These are standard (i.e., typically applicable) operating procedures which may be varied or changed asrequired, dependent upon site conditions, equipment limitations or limitations imposed by the procedure.In all instances, the actual procedures used should be documented and described in an appropriate sitereport.

Mention of trade names or commercial products does not constitute U.S. Environmental Protection Agency(EPA) endorsement or recommendation for use.

2.0 METHOD SUMMARY

Soil samples may be collected using a variety of methods and equipment depending on the depth of thedesired sample, the type of sample required (disturbed vs. undisturbed), and the soil type. Near-surfacesoils may be easily sampled using a spade, trowel, and scoop. Sampling at greater depths may beperformed using a hand auger, continuous flight auger, a trier, a split-spoon, or, if required, a backhoe.

3.0 SAMPLE PRESERVATION, CONTAINERS, HANDLING, AND STORAGE

Chemical preservation of solids is not generally recommended. Samples should, however, be cooled andprotected from sunlight to minimize any potential reaction. The amount of sample to be collected andproper sample container type are discussed in ERT/REAC SOP #2003 Rev. 0.0 08/11/94, Sample Storage,Preservation and Handling.

4.0 INTERFERENCES AND POTENTIAL PROBLEMS

There are two primary potential problems associated with soil sampling - cross contamination of samplesand improper sample collection. Cross contamination problems can be eliminated or minimized throughthe use of dedicated sampling equipment. If this is not possible or practical, then decontamination ofsampling equipment is necessary. Improper sample collection can involve using contaminated equipment,disturbance of the matrix resulting in compaction of the sample, or inadequate homogenization of thesamples where required, resulting in variable, non-representative results.

5.0 EQUIPMENT

000060





Soil sampling equipment includes the following:

C Maps/plot planC Safety equipment, as specified in the site-specific Health and Safety PlanC Survey equipment or global positioning system (GPS) to locate sampling pointsC Tape measureC Survey stakes or flagsC Camera and filmC Stainless steel, plastic, or other appropriate homogenization bucket, bowl or panC Appropriate size sample containersC Ziplock plastic bagsC LogbookC LabelsC Chain of Custody records and custody sealsC Field data sheets and sample labelsC Cooler(s)C IceC VermiculiteC Decontamination supplies/equipmentC Canvas or plastic sheetC Spade or shovelC SpatulaC ScoopC Plastic or stainless steel spoonsC Trowel(s)C Continuous flight (screw) augerC Bucket augerC Post hole augerC Extension rodsC T-handleC Sampling trierC Thin wall tube samplerC Split spoonsC Vehimeyer soil sampler outfit

- Tubes- Points- Drive head- Drop hammer- Puller jack and grip

C Backhoe

6.0 REAGENTS

000061





Reagents are not used for the preservation of soil samples. Decontamination solutions are specified inERT/REAC SOP #2006 Rev. 0.0 08/11/94, Sampling Equipment Decontamination, and the site specificwork plan.

7.0 PROCEDURES

7.1 Preparation

1. Determine the extent of the sampling effort, the sampling methods to be employed, and thetypes and amounts of equipment and supplies required.

2. Obtain necessary sampling and monitoring equipment.

3. Decontaminate or pre-clean equipment, and ensure that it is in working order.

4. Prepare schedules and coordinate with staff, client, and regulatory agencies, if appropriate.

5. Perform a general site survey prior to site entry in accordance with the site specific Healthand Safety Plan.

6. Use stakes, flagging, or buoys to identify and mark all sampling locations. Specific sitefactors, including extent and nature of contaminant, should be considered when selectingsample location. If required, the proposed locations may be adjusted based on site access,property boundaries, and surface obstructions. All staked locations should be utility-clearedby the property owner or the On-Scene-Coordinator (OSC) prior to soil sampling; andutility clearance should always be confirmed before beginning work.

7.2 Sample Collection

7.2.1 Surface Soil Samples

Collection of samples from near-surface soil can be accomplished with tools such asspades, shovels, trowels, and scoops. Surface material is removed to the requireddepth and a stainless steel or plastic scoop is then used to collect the sample.

This method can be used in most soil types but is limited to sampling at or near theground surface. Accurate, representative samples can be collected with this proceduredepending on the care and precision demonstrated by the sample team member. A flat,pointed mason trowel to cut a block of the desired soil is helpful when undisturbedprofiles are required. Tools plated with chrome or other materials should not be used.Plating is particularly common with garden implements such as potting trowels.

The following procedure is used to collect surface soil samples:

000062





1. Carefully remove the top layer of soil or debris to the desired sample depthwith a pre-cleaned spade.

2. Using a pre-cleaned, stainless steel scoop, plastic spoon, or trowel, remove anddiscard a thin layer of soil from the area which came in contact with the spade.

3. If volatile organic analysis is to be performed, transfer the sample directly intoan appropriate, labeled sample container with a stainless steel lab spoon, orequivalent and secure the cap tightly. Place the remainder of the sample intoa stainless steel, plastic, or other appropriate homogenization container, andmix thoroughly to obtain a homogenous sample representative of the entiresampling interval. Then, either place the sample into appropriate, labeledcontainers and secure the caps tightly; or, if composite samples are to becollected, place a sample from another sampling interval or location into thehomogenization container and mix thoroughly. When compositing is complete,place the sample into appropriate, labeled containers and secure the capstightly.

7.2.2 Sampling at Depth with Augers and Thin Wall Tube Samplers

This system consists of an auger, or a thin-wall tube sampler, a series of extensions,and a "T" handle (Figure 1, Appendix A). The auger is used to bore a hole to adesired sampling depth, and is then withdrawn. The sample may be collected directlyfrom the auger. If a core sample is to be collected, the auger tip is then replaced witha thin wall tube sampler. The system is then lowered down the borehole, and driveninto the soil to the completion depth. The system is withdrawn and the core iscollected from the thin wall tube sampler.

Several types of augers are available; these include: bucket type, continuous flight(screw), and post-hole augers. Bucket type augers are better for direct samplerecovery because they provide a large volume of sample in a short time. Whencontinuous flight augers are used, the sample can be collected directly from theflights. The continuous flight augers are satisfactory when a composite of thecomplete soil column is desired. Post-hole augers have limited utility for samplecollection as they are designed to cut through fibrous, rooted, swampy soil and cannotbe used below a depth of approximately three feet.

The following procedure is used for collecting soil samples with the auger:

1. Attach the auger bit to a drill rod extension, and attach the "T" handle to thedrill rod.

000063





2. Clear the area to be sampled of any surface debris (e.g., twigs, rocks, litter).It may be advisable to remove the first three to six inches of surface soil for anarea approximately six inches in radius around the drilling location.

3. Begin augering, periodically removing and depositing accumulated soils ontoa plastic sheet spread near the hole. This prevents accidental brushing of loosematerial back down the borehole when removing the auger or adding drill rods.It also facilitates refilling the hole, and avoids possible contamination of thesurrounding area.

4. After reaching the desired depth, slowly and carefully remove the auger fromthe hole. When sampling directly from the auger, collect the sample after theauger is removed from the hole and proceed to Step 10.

5. Remove auger tip from the extension rods and replace with a pre-cleaned thinwall tube sampler. Install the proper cutting tip.

6. Carefully lower the tube sampler down the borehole. Gradually force the tubesampler into the soil. Do not scrape the borehole sides. Avoid hammering therods as the vibrations may cause the boring walls to collapse.

7. Remove the tube sampler, and unscrew the drill rods.

8. Remove the cutting tip and the core from the device.

9. Discard the top of the core (approximately 1 inch), as this possibly representsmaterial collected before penetration of the layer of concern. Place theremaining core into the appropriate labeled sample container. Samplehomogenization is not required.

10. If volatile organic analysis is to be performed, transfer the sample into anappropriate, labeled sample container with a stainless steel lab spoon, orequivalent and secure the cap tightly. Place the remainder of the sample intoa stainless steel, plastic, or other appropriate homogenization container, andmix thoroughly to obtain a homogenous sample representative of the entiresampling interval. Then, either place the sample into appropriate, labeledcontainers and secure the caps tightly; or, if composite samples are to becollected, place a sample from another sampling interval into thehomogenization container and mix thoroughly.

When compositing is complete, place the sample into appropriate, labeledcontainers and secure the caps tightly.

000064





11. If another sample is to be collected in the same hole, but at a greater depth,reattach the auger bit to the drill and assembly, and follow steps 3 through 11,making sure to decontaminate the auger and tube sampler between samples.

12. Abandon the hole according to applicable state regulations. Generally, shallowholes can simply be backfilled with the removed soil material.

7.2.3 Sampling with a Trier

The system consists of a trier, and a "T" handle. The auger is driven into the soil tobe sampled and used to extract a core sample from the appropriate depth.

The following procedure is used to collect soil samples with a sampling trier:

1. Insert the trier (Figure 2, Appendix A) into the material to be sampled at a 0o

to 45o angle from horizontal. This orientation minimizes the spillage ofsample.

2. Rotate the trier once or twice to cut a core of material.

3. Slowly withdraw the trier, making sure that the slot is facing upward.

4. If volatile organic analyses are required, transfer the sample into anappropriate, labeled sample container with a stainless steel lab spoon, orequivalent and secure the cap tightly. Place the remainder of the sample intoa stainless steel, plastic, or other appropriate homogenization container, andmix thoroughly to obtain a homogenous sample representative of the entiresampling interval. Then, either place the sample into appropriate, labeledcontainers and secure the caps tightly; or, if composite samples are to becollected, place a sample from another sampling interval into thehomogenization container and mix thoroughly. When compositing is complete,place the sample into appropriate, labeled containers and secure the capstightly.

7.2.4 Sampling at Depth with a Split Spoon (Barrel) Sampler

Split spoon sampling is generally used to collect undisturbed soil cores of 18 or 24inches in length. A series of consecutive cores may be extracted with a split spoonsampler to give a complete soil column profile, or an auger may be used to drill downto the desired depth for sampling. The split spoon is then driven to its sampling depththrough the bottom of the augured hole and the core extracted.

When split spoon sampling is performed to gain geologic information, all work should

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be performed in accordance with ASTM D1586-98, “Standard Test Method forPenetration Test and Split-Barrel Sampling of Soils”.

The following procedures are used for collecting soil samples with a split spoon:

1. Assemble the sampler by aligning both sides of barrel and then screwing thedrive shoe on the bottom and the head piece on top.

2. Place the sampler in a perpendicular position on the sample material.

3. Using a well ring, drive the tube. Do not drive past the bottom of the headpiece or compression of the sample will result.

4. Record in the site logbook or on field data sheets the length of the tube used topenetrate the material being sampled, and the number of blows required toobtain this depth.

5. Withdraw the sampler, and open by unscrewing the bit and head and splittingthe barrel. The amount of recovery and soil type should be recorded on theboring log. If a split sample is desired, a cleaned, stainless steel knife shouldbe used to divide the tube contents in half, longitudinally. This sampler istypically available in 2 and 3 1/2 inch diameters. A larger barrel may benecessary to obtain the required sample volume.

6. Without disturbing the core, transfer it to appropriate labeled samplecontainer(s) and seal tightly.

7.2.5 Test Pit/Trench Excavation

A backhoe can be used to remove sections of soil, when detailed examination of soilcharacteristics are required. This is probably the most expensive sampling methodbecause of the relatively high cost of backhoe operation.

The following procedures are used for collecting soil samples from test pits ortrenches:

1. Prior to any excavation with a backhoe, it is important to ensure that allsampling locations are clear of overhead and buried utilities.

2. Review the site specific Health & Safety plan and ensure that all safetyprecautions including appropriate monitoring equipment are installed asrequired.

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3. Using the backhoe, excavate a trench approximately three feet wide andapproximately one foot deep below the cleared sampling location. Placeexcavated soils on plastic sheets. Trenches greater than five feet deep must besloped or protected by a shoring system, as required by OSHA regulations.

4. A shovel is used to remove a one to two inch layer of soil from the vertical faceof the pit where sampling is to be done.

5. Samples are taken using a trowel, scoop, or coring device at the desiredintervals. Be sure to scrape the vertical face at the point of sampling to removeany soil that may have fallen from above, and to expose fresh soil for sampling.In many instances, samples can be collected directly from the backhoe bucket.

6. If volatile organic analyses are required, transfer the sample into anappropriate, labeled sample container with a stainless steel lab spoon, orequivalent and secure the cap tightly. Place the remainder of the sample intoa stainless steel, plastic, or other appropriate homogenization container, andmix thoroughly to obtain a homogenous sample representative of the entiresampling interval. Then, either place the sample into appropriate, labeledcontainers and secure the caps tightly; or, if composite samples are to becollected, place a sample from another sampling interval into thehomogenization container and mix thoroughly. When compositing is complete,place the sample into appropriate, labeled containers and secure the capstightly.

7. Abandon the pit or excavation according to applicable state regulations.Generally, shallow excavations can simply be backfilled with the removed soilmaterial.

8.0 CALCULATIONS

This section is not applicable to this SOP.


There are no specific quality assurance (QA) activities which apply to the implementation of theseprocedures. However, the following QA procedures apply:

1. All data must be documented on field data sheets or within site logbooks.

2. All instrumentation must be operated in accordance with operating instructions as supplied by themanufacturer, unless otherwise specified in the work plan. Equipment checkout and calibration

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activities must occur prior to sampling/operation, and they must be documented.




When working with potentially hazardous materials, follow U.S. EPA, OHSA and corporate health andsafety procedures, in addition to the procedures specified in the site specific Health & Safety Plan..

12.0 REFERENCES

Mason, B.J. 1983. Preparation of Soil Sampling Protocol: Technique and Strategies. EPA-600/4-83-020.

Barth, D.S. and B.J. Mason. 1984. Soil Sampling Quality Assurance User's Guide. EPA-600/4-84-043.

U.S. Environmental Protection Agency. 1984 Characterization of Hazardous Waste Sites - A MethodsManual: Volume II. Available Sampling Methods, Second Edition. EPA-600/4-84-076.

de Vera, E.R., B.P. Simmons, R.D. Stephen, and D.L. Storm. 1980. Samplers and Sampling Proceduresfor Hazardous Waste Streams. EPA-600/2-80-018.

ASTM D 1586-98, ASTM Committee on Standards, Philadelphia, PA.

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APPENDIX AFigures

SOP #2012February 2000

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FIGURE 1. Sampling Augers

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FIGURE 2. Sampling Trier

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Appendix D

EPA ERT SOP 2009 Drum Sampling

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SOP#: 2009DATE: 11/16/94

REV. #: 0.0 DRUM SAMPLING

1.0 SCOPE AND APPLICATION 3.0 SAMPLE PRESERVATION,

The purpose of this standard operating procedure(SOP) is to provide technical guidance onimplementing safe and cost-effective response actionsat hazardous waste sites containing drums withunknown contents. Container contents are sampledand characterized for disposal, bulking, recycling,segregation, and classification purposes.

These are standard (i.e., typically applicable)operating procedures which may be varied or changedas required, dependent on site conditions, equipmentlimitations or limitations imposed by the procedure.In all instances, the ultimate procedures employedshould be documented and associated with the finalreport.

Mention of trade names or commercial products doesnot constitute U.S. Environmental Protection Agency(U.S. EPA) endorsement or recommendation for use.

2.0 METHOD SUMMARY

Prior to sampling, drums must be excavated, (ifnecessary), inspected, staged, and opened. Drumexcavation must be performed by qualified personnel.Inspection involves the observation and recording ofvisual qualities of each drum and any characteristicspertinent to the classification of the drum's contents.Staging involves the physical grouping of drumsaccording to classifications established during thephysical inspection. Opening of closed drums can beperformed manually or remotely. Remote drumopening is recommended for worker safety. The mostwidely used method of sampling a drum involves theuse of a glass thief. This method is quick, simple,relatively inexpensive, and requires nodecontamination. The contents of a drum can befurther characterized by performing various field tests.

CONTAINERS, HANDLING,AND STORAGE

Samples collected from drums are considered wastesamples and as such, adding preservatives is notrequired due to the potential reaction of the samplewith the preservative. Samples should, however, becooled to 4 C and protected from sunlight in order too

minimize any potential reaction due to the lightsensitivity of the sample.

Sample bottles for collection of waste liquids, sludges,or solids are typically wide mouth amber jars withTeflon-lined screw caps. Actual volume required foranalysis should be determined in conjunction with thelaboratory performing the analysis.

Waste sample handling procedures should be asfollows:

1. Label the sample container with theappropriate sample label and complete theappropriate field data sheet(s). Place samplecontainer into two resealable plastic bags.

2. Place each bagged sample container into ashipping container which has been lined withplastic. Pack the container with enough non-combustible, absorbent, cushioning materialto minimize the possibility of containersbreaking, and to absorb any material whichmay leak.

Note: Depending on the nature and quantityof the material to be shipped, differentpackaging may be required. Thetransportation company or ashipping/receiving expert should beconsulted prior to packing the samples.

3. Complete a chain of custody record for eachshipping container, place into a resealable

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plastic bag, and affix to the inside lid of the tube (3 meters long) is positioned at the vapor spaceshipping container. of the drum. A rigid, hooking device attached to the

4. Secure and custody seal the lid of the in place. The spear is inserted in the tube andshipping container. Label the shipping positioned against the drum wall. A sharp blow oncontainer appropriately and arrange for the the end of the spear drives the sharpened tip throughappropriate transportation mode consistent the drum and the gas vents along the grooves.with the type of hazardous waste involved. Venting should be done from behind a wall or

4.0 INTERFERENCES ANDPOTENTIAL PROBLEMS

If buried drums are suspected, geophysicalinvestigation techniques such as magnetometry orground penetrating radar may be employed in anattempt to determine the location and depth of drums.During excavation, the soil must be removed withgreat caution to minimize the potential for drumrupture.

Until the contents are characterized, samplingpersonnel should assume that unlabelled drumscontain hazardous materials. Labelled drums arefrequently mislabelled, especially drums that arereused. Because a drum's label may not accuratelydescribe its contents, extreme caution must beexercised when working with or around drums.

If a drum which contains a liquid cannot be movedwithout rupture, its contents may be immediatelytransferred to a sound drum using an appropriatemethod of transfer based on the type of waste. In anycase, preparations should be made to contain the spill(i.e., spill pads, dike, etc.) should one occur.

If a drum is leaking, open, or deteriorated, then it mustbe placed immediately in overpack containers.

The practice of tapping drums to determine theircontents is neither safe nor effective and should not beused if the drums are visually overpressurized or ifshock-sensitive materials are suspected. A laserthermometer may be effective in order to determinethe level of the drum contents via surface temperaturedifferences.

Drums that have been overpressurized to the extentthat the head is swollen several inches above the levelof the chime should not be moved. A number ofdevices have been developed for venting criticallyswollen drums. One method that has proven to beeffective is a tube and spear device. A light aluminum

tube, goes over the chime and holds the tube securely

barricade. Once the pressure has been relieved, thebung can be removed and the drum sampled.

Because there is potential for accidents to occurduring handling, particularly initial handling, drumsshould only be handled if necessary. All personnelshould be warned of the hazards prior to handlingdrums. Overpack drums and an adequate volume ofabsorbent material should be kept near areas whereminor spills may occur. Where major spills mayoccur, a containment berm adequate to contain theentire volume of liquid in the drums should beconstructed before any handling takes place. If drumcontents spill, personnel trained in spill responseshould be used to isolate and contain the spill.

5.0 EQUIPMENT/APPARATUS

The following are standard materials and equipmentrequired for sampling:

C Personal protection equipmentC Wide-mouth amber glass jars with Teflon

cap liner, approximately 500 mL volumeC Other appropriate sample jarsC Uniquely numbered sample identification

labels with corresponding data sheetsC Drum/Tank Sampling Data Sheets and Field

Test Data Sheets for Drum/Tank SamplingC Chain of Custody recordsC Decontamination materialsC Glass thieving tubes or COLIWASAC Coring deviceC Stainless steel spatula or spoonsC Laser thermometerC Drum overpacksC Absorbent material for spillsC Drum opening devices

Bung Wrench

A common method for opening drumsmanually is using a universal bung wrench.These wrenches have fittings made to

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remove nearly all commonly encountered Pneumatic Devicesbungs. They are usually constructed of anon-sparking metal alloy (i.e., brass, A pneumatic bung remover consists of abronze/manganese, aluminum, etc.) compressed air supply that is controlled by aformulated to reduce the likelihood of sparks. two-stage regulator. A high pressure air lineThe use of a "NON-SPARKING" wrench of desired length delivers compressed air todoes not completely eliminate the possibility a pneumatic drill, which is adapted to turnof a spark being produced. bung fitting selected to fit the bung to be

Drum Deheader has been designed to position and align the

One means by which a drum can be opened bracketing system must be attached to themanually when a bung is not removable with drum before the drill can be operated. Oncea bung wrench is by using a drum deheader. the bung has been loosened, the bracketingThis tool is constructed of forged steel with system must be removed before the drum canan alloy steel blade and is designed to cut the be sampled. This remote bung opener doeslid of a drum off or part way off by means of not permit the slow venting of the container,a scissors-like cutting action. A limitation of and therefore appropriate precautions mustthis device is that it can be attached only to be taken. It also requires the container to beclosed head drums. Drums with removable upright and relatively level. Bungs that areheads must be opened by other means. rusted shut cannot be removed with this

Hand Pick, Pickaxe, and Hand Spike

These tools are usually constructed of brassor a non-sparking alloy with a sharpenedpoint that can penetrate the drum lid or headwhen the tool is swung. The hand picks orpickaxes that are most commonly used arecommercially available; whereas, the spikesare generally uniquely fabricated four footlong poles with a pointed end.

Backhoe Spike

Another means used to open drums remotelyfor sampling is a metal spike attached orwelded to a backhoe bucket. This method isvery efficient and is often used in large-scaleoperations.

Hydraulic Drum Opener

Recently, remotely operated hydraulicdevices have been fabricated to open drums.This device uses hydraulic pressure to forcea non-sparking spike through the wall of adrum. It consists of a manually operatedpump which pressurizes fluid through alength of hydraulic line.

removed. An adjustable bracketing system

pneumatic drill over the bung. This

device.

6.0 REAGENTS

Reagents are not typically required for preservingdrum samples. However, reagents will be utilized fordecontamination of sampling equipment.

7.0 PROCEDURES

7.1 Preparation

1. Determine the extent of the sampling effort,the sampling methods to be employed, andthe types and amounts of equipment andsupplies needed.

2. Obtain necessary sampling and monitoringequipment.

3. Decontaminate or preclean equipment, andensure that it is in working order.

4. Prepare scheduling and coordinate with staff,clients, and regulatory agency, if appropriate.

5. Perform a general site survey prior to siteentry in accordance with the site specificHealth and Safety Plan.

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6. Use stakes, flagging, or buoys to identify and 2. Symbols, words, or other markings on themark all sampling locations. If required the drum indicating hazards (i.e., explosive,proposed locations may be adjusted based on radioactive, toxic, flammable), or furthersite access, property boundaries, and surface identifying the drums.obstructions.

7.2 Drum Excavation

If it is presumed that buried drums are on-site andprior to beginning excavation activities, geophysicalinvestigation techniques should be utilized toapproximate the location and depth of the drums. Inaddition, it is important to ensure that all locationswhere excavation will occur are clear of utility lines,pipes and poles (subsurface as well as above surface).

Excavating, removing, and handling drums aregenerally accomplished with conventional heavyconstruction equipment. These activities should beperformed by an equipment operator who hasexperience in drum excavation. During excavationactivities, drums must be approached in a manner thatwill avoid digging directly into them.

The soil around the drum should be excavated withnon-sparking hand tools or other appropriate meansand as the drums are exposed, a visual inspectionshould be made to determine the condition of thedrums. Ambient air monitoring should be done todetermine the presence of unsafe levels of volatileorganics, explosives, or radioactive materials. Basedon this preliminary visual inspection, the appropriatemode of drum excavation and handling may bedetermined.

Drum identification and inventory should begin beforeexcavation. Information such as location, date ofremoval, drum identification number, overpack status,and any other identification marks should be recordedon the Drum/Tank Sampling Data Sheet (Attachment1, Appendix A).

7.3 Drum Inspection

Appropriate procedures for handling drums depend onthe contents. Thus, prior to any handling, drumsshould be visually inspected to gain as muchinformation as possible about their contents. Thedrums should be inspected for the following:

1. Drum condition, corrosion, rust, punctures,bungs, and leaking contents.

3. Signs that the drum is under pressure.

4. Shock sensitivity.

Monitoring should be conducted around the drumsusing instruments such as radiation meters, organicvapor analyzers (OVA) and combustible gasindicators (CGI).

Survey results can be used to classify the drums intocategories, for instance:

C RadioactiveC Leaking/deterioratingC BulgingC Lab packsC Explosive/shock sensitiveC Empty

All personnel should assume that unmarked drumscontain hazardous materials until their contents havebeen categorized. Once a drum has been visuallyinspected and any immediate hazard has beeneliminated by overpacking or transferring the drum'scontents, the drum is affixed with a numbered tag andtransferred to a staging area. Color-coded tags, labelsor bands should be used to identify the drum'scategory based on visual inspection. A description ofeach drum, its condition, any unusual markings, thelocation where it was buried or stored, and fieldmonitoring information are recorded on a Drum/TankSampling Data Sheet (Attachment 1, Appendix A).This data sheet becomes the principal record keepingtool for tracking the drum on-site.

7.4 Drum Staging

Prior to sampling, the drums should be staged to alloweasy access. Ideally, the staging area should belocated just far enough from the drum opening area toprevent a chain reaction if one drum should explode orcatch fire when opened.

During staging, the drums should be physicallyseparated into the following categories: thosecontaining liquids, those containing solids, thosecontaining lab packs, and those which are empty.

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This is done because the strategy for sampling and drums are structurally sound (no evidence of bulginghandling drums/containers in each of these categories or deformation) and their contents are known to bewill be different. This may be achieved by visual non-shock sensitive, non-reactive, non-explosive orinspection of the drum and its labels, codes, etc. non-flammable. If opening the drum with bungSolids and sludges are typically disposed of in open wrenches is deemed safe, then certain procedurestop drums. Closed head drums with a bung opening should be implemented to minimize the hazard:generally contain liquid.

Where there is good reason to suspect that drums protective gear.contain radioactive, explosive, or shock-sensitive C Drums should be positioned upright with thematerials, these drums should be staged in a separate, bung up, or, for drums with bungs on theisolated area. Placement of explosives and shock- side, laid on their sides with the bung plugssensitive materials in diked and fenced areas will up.minimize the hazard and the adverse effects of any C The wrenching motion should be a slow,premature detonation of explosives. steady pull across the drum. If the length of

Where space allows, the drum opening area should be leverage for unscrewing the plug, a "cheaterphysically separated from the drum removal and drum bar" can be attached to the handle to improvestaging operations. Drums are moved from the leverage.staging area to the drum opening area one at a timeusing forklift trucks equipped with drum grabbers ora barrel grappler. In a large-scale drum handlingoperation, drums may be conveyed to the drumopening area using a roller conveyor. Drums may berestaged as necessary after opening and sampling.

7.5 Drum Opening

There are three basic techniques available for openingdrums at hazardous waste sites:

C Manual opening with non-sparking bungwrenches

C Drum deheadingC Remote drum puncturing or bung removal

The choice of drum opening techniques andaccessories depends on the number of drums to beopened, their waste contents, and physical condition.Remote drum opening equipment should always beconsidered in order to protect worker safety. UnderOSHA 1910.120, manual drum opening with bungwrenches or deheaders should be performed ONLYwith structurally sound drums and waste contents thatare known to be non-shock sensitive, non-reactive,non-explosive, and non-flammable.

7.5.1 Manual Drum Opening with a BungWrench 7.5.3 Manual Drum Opening with a Hand

Manual drum opening with bung wrenches (Figure 1,Appendix B) should not be performed unless the

C Field personnel should be fully outfitted with

the bung wrench handle provides inadequate

7.5.2 Manual Drum Opening with a DrumDeheader

Drums are opened with a drum deheader (Figure 2,Appendix B) by first positioning the cutting edge justinside the top chime and then tightening theadjustment screw so that the deheader is held againstthe side of the drum. Moving the handle of thedeheader up and down while sliding the deheaderalong the chime will enable the entire top to be rapidlycut off if so desired. If the top chime of a drum hasbeen damaged or badly dented it may not be possibleto cut the entire top off. Since there is always thepossibility that a drum may be under pressure, theinitial cut should be made very slowly to allow for thegradual release of any built-up pressure. A safertechnique would be to employ a remote method priorto using the deheader.

Self-propelled drum openers which are eitherelectrically or pneumatically driven are available andcan be used for quicker and more efficient deheading.

The drum deheader should be decontaminated, asnecessary, after each drum is opened to avoid crosscontamination and/or adverse chemical reactions fromincompatible materials.

Pick, Pickaxe, or Spike

When a drum must be opened and neither a bung

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wrench nor a drum deheader is suitable, then it can beopened for sampling by using a hand pick, pickaxe, orspike (Figure 3, Appendix B). Often the drum lid orhead must be hit with a great deal of force in order topenetrate it. Because of this, the potential for splashor spraying is greater than with other opening methodsand therefore, this method of drum opening is notrecommended, particularly when opening drumscontaining liquids. Some spikes used have beenmodified by the addition of a circular splash plate nearthe penetrating end. This plate acts as a shield andreduces the amount of splash in the direction of theperson using the spike. Even with this shield, goodsplash gear is essential.

Since drums, some of which may be under pressure,cannot be opened slowly with these tools, spray fromdrums is common and appropriate safety measuresmust be taken. The pick or spike should bedecontaminated after each drum is opened to avoidcross contamination and/or adverse chemical reactionfrom incompatible materials.

7.5.4 Remote Drum Opening with aBackhoe Spike

Remotely operated drum opening tools are the safestavailable means of drum opening. Remote drumopening is slow, but provides a high degree of safetycompared to manual methods of opening.

In the opening area, drums should be placed in rowswith adequate aisle space to allow ease in backhoemaneuvering. Once staged, the drums can be quicklyopened by punching a hole in the drum head or lidwith the spike.

The spike (Figure 4, Appendix B) should bedecontaminated after each drum is opened to preventcross contamination and/or adverse reaction fromincompatible material. Even though some splash orspray may occur when this method is used, theoperator of the backhoe can be protected by mountinga large shatter-resistant shield in front of the operator'scage. This combined with the normal personalprotection gear should be sufficient to protect theoperator. Additional respiratory protection can beafforded by providing the operator with an on-boardairline system.

7.5.5 Remote Drum Opening withHydraulic Devices

A piercing device with a non-sparking, metal point isattached to the end of a hydraulic line and is pushedinto the drum by the hydraulic pressure (Figure 5,Appendix B). The piercing device can be attached sothat a hole for sampling can be made in either the sideor the head of the drum. Some of the metal piercersare hollow or tube-like so that they can be left in placeif desired and serve as a permanent tap or samplingport. The piercer is designed to establish a tight sealafter penetrating the container.

7.5.6 Remote Drum Opening withPneumatic Devices

Pneumatically-operated devices utilizing compressedair have been designed to remove drum bungsremotely (Figure 6, Appendix B). Prior to opening thedrum, a bung fitting must be selected to fit the bung tobe removed. The adjustable bracketing system is thenattached to the drum and the pneumatic drill is alignedover the bung. This must be done before the drill canbe operated. The operator then moves away from thedrum to operate the equipment. Once the bung hasbeen loosened, the bracketing system must beremoved before the drum can be sampled. Thisremote bung opener does not permit the slow ventingof the container, and therefore appropriate precautionsmust be taken. It also requires the container to beupright and relatively level. Bungs that are rustedshut cannot be removed with this device.

7.6 Drum Sampling

After the drum has been opened, preliminarymonitoring of headspace gases should be performedfirst with an explosimeter/oxygen meter. Afterwards,an OVA or other instruments should be used. Ifpossible, these instruments should be intrinsicallysafe. In most cases it is impossible to observe thecontents of these sealed or partially sealed drums.Since some layering or stratification is likely in anysolution left undisturbed, a sample that represents theentire depth of the drum must be taken.

When sampling a previously sealed drum, a checkshould be made for the presence of a bottom sludge.This is easily accomplished by measuring the depth toapparent bottom then comparing it to the knowninterior depth.

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7.6.1 Glass Thief Sampler

The most widely used implement for sampling drumliquids is a glass tube commonly referred to as a glassthief (Figure 7, Appendix B). This tool is costeffective, quick, and disposable. Glass thieves aretypically 6mm to 16mm I.D. and 48 inches long.

Procedures for Use:

1. Remove the cover from the sample container.

2. Insert glass tubing almost to the bottom ofthe drum or until a solid layer is encountered.About one foot of tubing should extendabove the drum.

3. Allow the waste in the drum to reach its The Composite Liquid Waste Sampler (COLIWASA)natural level in the tube. and modifications thereof are equipment that collect

4. Cap the top of the sampling tube with a it in the transfer tube until delivery to the sampletapered stopper or thumb, ensuring liquid bottle. The COLIWASA (Figure 8, Appendix B) is adoes not come into contact with stopper. much cited sampler designed to permit representative

5. Carefully remove the capped tube from the containerized wastes. One configuration consists ofdrum and insert the uncapped end into the a 152 cm by 4 cm I.D. section of tubing with aappropriate sample container. neoprene stopper at one end attached by a rod running

6. Release stopper and allow the glass thief to other end. drain until the container is approximatelytwo-thirds full. Manipulation of the locking mechanism opens and

7. Remove tube from the sample container, neoprene stopper. One model of the COLIWASA isbreak it into pieces and place the pieces in shown in Appendix B; however, the design can bethe drum. modified and/or adapted somewhat to meet the needs

8. Cap the sample container tightly and label it.Place the sample container into a carrier. The major drawbacks associated with using a

9. Replace the bung or place plastic over the sampler is difficult to decontaminate in the field anddrum. its high cost in relation to alternative procedures (glass

10. Log all samples in the site logbook and on has applications, however, especially in instancesDrum/Tank Sampling Data Sheets. where a true representation of a multiphase waste is

11. Perform hazard categorization analyses ifincluded in the project scope. Procedures for Use

12. Transport the sample to the decontamination 1. Put the sampler in the open position byzone and package it for transport to the placing the stopper rod handle in the T-analytical laboratory, as necessary. position and pushing the rod down until theComplete chain of custody records. handle sits against the sampler's locking

In many instances a drum containing waste materialwill have a sludge layer on the bottom. Slow insertionof the sample tube into this layer; then a gradualwithdrawal will allow the sludge to act as a bottomplug to maintain the fluid in the tube. The plug can begently removed and placed into the sample containerby the use of a stainless steel lab spoon.

It should be noted that in some instances disposal ofthe tube by breaking it into the drum may interferewith eventual plans for the removal of its contents.The use of this technique should be cleared with theproject officer or other glass thief disposal techniquesshould be evaluated.

7.6.2 COLIWASA Sampler

a sample from the full depth of a drum and maintain

sampling of multiphase wastes from drums and other

the length of the tube to a locking mechanism at the

closes the sampler by raising and lowering the

of the sampler.

COLIWASA concern decontamination and costs. The

tubes) make it an impractical throwaway item. It still

absolutely necessary.

block.

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2. Slowly lower the sampler into the liquid Procedures for use:waste. Lower the sampler at a rate thatpermits the levels of the liquid inside and 1. Assemble the sampling equipment.outside the sampler tube to be about thesame. If the level of the liquid in the sample 2. Remove the cover from the sample container.tube is lower than that outside the sampler,the sampling rate is too fast and will result in 3. Insert the sampling device to the bottom ofa non-representative sample. the drum. The extensions and the "T" handle

3. When the sampler stopper hits the bottom ofthe waste container, push the sampler tube 4. Rotate the sampling device to cut a core ofdownward against the stopper to close the material.sampler. Lock the sampler in the closedposition by turning the T-handle until it is 5. Slowly withdraw the sampling device so thatupright and one end rests tightly on the as much sample material as possible islocking block. retained within it.

4. Slowly withdraw the sample from the waste 6. Transfer the sample to the appropriatecontainer with one hand while wiping the sample container, and label it. A stainlesssampler tube with a disposable cloth or rag steel spoon or scoop may be used aswith the other hand. necessary.

5. Carefully discharge the sample into theappropriate sample container by slowly 7. Cap the sample container tightly and place itpulling the lower end of the T-handle away in a carrier.from the locking block while the lower endof the sampler is positioned in a sample 8. Replace the bung or place plastic over thecontainer. drum.

6. Cap the sample container tightly and label it. 9. Log all samples in the site log book and onPlace the sample container in a carrier. Drum/Tank Sampling Data Sheets.

7. Replace the bung or place plastic over the 10. Perform hazard categorization analyses ifdrum. included in the project scope.

8. Log all samples in the site logbook and on 11. Transport the sample to the decontaminationDrum/Tank Sampling Data Sheets. zone and package it for transport to the

9. Perform hazard categorization analyses if Complete chain of custody records.included in the project scope.

10. Transport the sample to the decontaminationzone and package for transport to theanalytical laboratory, as necessary.Complete the Chain of Custody records.

7.6.3 Coring Device

A coring device may be used to sample drum solids. regarding drum staging or restaging, bulking orSamples should be taken from different areas within compositing of the drum contents.the drum. This sampler consists of a series ofextensions, a T- handle, and the coring device.

should extend above the drum.

analytical laboratory, as necessary.

7.7 Hazard Categorization

The goal of characterizing or categorizing the contentsof drums is to obtain a quick, preliminary assessmentof the types and levels of pollutants contained in thedrums. These activities generally involve rapid, non-rigorous methods of analysis. The data obtained fromthese methods can be used to make decisions

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As a first step in obtaining these data, standard tests 1. All data must be documented on Chain ofshould be used to classify the drum contents into Custody records, Drum/Tank Sampling Datageneral categories such as auto-reactives, water Sheets, Field Test Data Sheet for Drum/Tankreactives, inorganic acids, organic acids, heavy Sampling, or within site logbooks.metals, pesticides, cyanides, inorganic oxidizers, andorganic oxidizers. In some cases, further analyses 2. All instrumentation must be operated inshould be conducted to more precisely identify the accordance with operating instructions asdrum contents. supplied by the manufacturer, unless

There are several methods available to perform these Equipment checkout and calibrationtests: activities must occur prior to

C the HazCat chemical identification system documented.R

C the Chlor-N-Oil Test KitC Spill-fyter Chemical Classifier StripsC Setaflash (for ignitability)

These methods must be performed according to themanufacturers' instructions and the results must bedocumented on the Field Test Data Sheet forDrum/Tank Sampling (Attachment 2, Appendix A).

Other tests which may be performed include:

C Water ReactivityC Specific Gravity Test (compared to water)C Water Solubility TestC pH of Aqueous Solution

The tests must be performed in accordance with theinstructions on the Field Test Data Sheet forDrum/Tank Sampling and results of the tests must bedocumented on these data sheets.

The specific methods that will be used for hazardcategorization must be documented in the QualityAssurance Work Plan.

8.0 CALCULATIONS



The following general quality assurance proceduresapply:

otherwise specified in the work plan.

sampling/operation, and they must be




When working with potentially hazardous materials,follow U.S. EPA, OSHA, and corporate health andsafety procedures.

More specifically, the opening of closed containers isone of the most hazardous site activities. Maximumefforts should be made to ensure the safety of thesampling team. Proper protective equipment and ageneral awareness of the possible dangers willminimize the risk inherent to sampling operations.Employing proper drum opening techniques andequipment will also safeguard personnel. The use ofremote sampling equipment whenever feasible ishighly recommended.

12.0 REFERENCES

Guidance Document for Cleanup of Surface Tank andDrum Sites, OSWER Directive 9380.0-3.

Drum Handling Practices at Hazardous Waste Sites,EPA-600/2-86-013.

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10

APPENDIX A

Attachments

ATTACHMENT 1. Drum/Tank Sampling Data Sheet

Samplers: Date:

Site Name: Work Order Number: 3347-040-001-

Container Number/Sample Number: REAC Task Leader:

SITE INFORMATION:

1. Terrain, drainage description:________________________________________________________________

2. Weather conditions (from observation):________________________________________________________

MET station on site: No Yes

CONTAINER INFORMATION:

1. Container type: Drum Tank Other:_________________________________________________

2. Container dimensions: Shape:________________________________________________________

Approximate size:_______________________________________________

3. Label present: NoYes:__________________________________________________________

Other Markings: ________________________________________________________________________________________________________________________________________________________________________________________________________________________

4. Spill or leak present: No Yes Dimensions:____________________________________________

5. Container location: (Circle one) N/A See Map Other: ____________________________________________________________________________________

________________________________________________________

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11

APPENDIX A (Cont’d)

Attachments

ATTACHMENT 1. Drum/Tank Sampling Data Sheet (cont’d)

SAMPLE INFORMATION:

1. Description: _____ liquid _____ solid (_____ powder or _____ crystals) _____ sludge

2. Color: _________________________ Vapors:_____________________ Other:_____________________________________________________________________________________

3. Local effects present: (damage - environmental,material)_____________________________________________

FIELD MONITORING:

1. PID: ____________________ Background (clean zone)

____________________ Probe used/Model used

____________________ Reading from container opening

2. FID: ____________________ Background (clean zone)


3. Radiation Meter:

____________________ Model used

____________________ Background (clean zone)


4. Explosimeter/Oxygen Meter:

____________________ Oxygen level from container opening

____________________ LEL level from container opening

000083

12


Attachments

ATTACHMENT 2. Field Test Data Sheet for Drum/Tank Sampling

Samplers: ______________________________ Date: ______________________

Site Name: _____________________________ Work Order Number: 3347-040-001-__________

Container Number/Sample Number: ______________ REAC Task Leader: ________________________

SAMPLE MONITORING INFORMATION:

1. PID: ____________________ Background (clean zone)

____________________ Probe used/Model used

____________________ Reading from sample

2. FID: ____________________ Background (clean zone)

____________________ Reading from sample

3. Radiation Meter: ________________ Model used

________________ Background (clean zone)

________________ Reading from sample

4. Explosimeter/Oxygen Meter: ____________ Oxygen level (sample)

____________ LEL level (sample)

SAMPLE DESCRIPTION:

________ Liquid ________ Solid ________ Sludge ________ Color ________ Vapors

WATER REACTIVITY:

1. Add small amount of sample to water: _____ bubbles _____ color change to _______________

_____ vapor formation _____ heat _____ No Change

SPECIFIC GRAVITY TEST (compared to water):

1. Add small amount of sample to water: _____ sinks _____ floats

2. If liquid sample sinks, screen for chlorinated compounds. If liquid sample floats and appears to be oily, screen for PCBs (Chlor-N-Oil kit).

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13


Attachments

ATTACHMENT 2. Field Test Data Sheet for Drum/Tank Sampling (cont'd)

CHLOR N OIL TEST KIT INFORMATION:

1. Test kit used for this sample: Yes No

2. Results: _____ PCB not present _____ PCB present, less than 50 ppm

_____ PCB present, greater than 50 ppm _____ 100% PCB present

WATER SOLUBILITY TEST:

1. Add approximately one part sample to five parts water. You may need to stir and heat gently. [DO NOT HEAT IF WATER REACTIVE!] Results: ________ total ________ partial ________ no solubility

pH OF AQUEOUS SOLUTION:

1. Using 0-14 pH paper, check pH of water/sample solution: ___________________.

SPILL-FYTER CHEMICAL CLASSIFIER STRIPS:

1. Acid/Base Risk: (Circle one) Color Change

Strong acid (0) RED

Moderately acidic (1-3) ORANGE

Weak acid (5) YELLOW

Neutral (7) GREEN

Moderately basic (9-11) Dark GREEN

Strong Base (13-14) Dark BLUE

2. Oxidizer Risk: (Circle one)

Not Present WHITE

Present BLUE, RED, OR ANY DIVERGENCE FROMWHITE

3. Fluoride Risk: (Circle one)

Not Present PINK

Present YELLOW

000085

14


Attachments


4. Petroleum Product, Organic Solvent Risk: (Circle one)

Not Present LIGHT BLUE

Present DARK BLUE

5. Iodine, Bromine, Chlorine Risk: (Circle one)

Not Present PEACH

Present WHITE OR YELLOW

SETAFLASH IGNITABILITY TEST:

140 F Ignitable: ________ Non-Ignitable ________ o

160 F Ignitable: ________ Non-Ignitable ________ o

______ Ignitable: ________ Non-Ignitable ________




Comments:________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

HAZCAT KIT TESTS:

1. Test: ____________________________________ Outcome:__________________________________

Comments:___________________________________________________________________________________

____________________________________________________________________________________________

2. Test: ____________________________________ Outcome:__________________________________

Comments:___________________________________________________________________________________

____________________________________________________________________________________________

000086

15


Attachments


3. Test: ____________________________________ Outcome:__________________________________

Comments:___________________________________________________________________________________

____________________________________________________________________________________________

4. Test: ____________________________________ Outcome:__________________________________

Comments:___________________________________________________________________________________

____________________________________________________________________________________________

5. Test: ____________________________________ Outcome:__________________________________

Comments:___________________________________________________________________________________

____________________________________________________________________________________________

HAZCAT PESTICIDES KIT:

Present: ________________________________ Not Present: _______________________________________

Comments: __________________________________________________________________________________

____________________________________________________________________________________________

____________________________________________________________________________________________

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16

APPENDIX B

Figures

Figure 1. Universal Bung Wrench

000088

17

APPENDIX B (Cont’d)

Figures

Figure 2. Drum Deheader

000089

18


Figures

Figure 3. Hand Pick, Pickaxe, and Hand Spike

000090

19


Figures

Figure 4. Backhoe Spike

000091

20


Figures

Figure 5. Hydraulic Drum Opener

000092

21


Figures

Figure 6. Pneumatic Bung Remover

000093

22


Figures

Figure 7. Glass Thief

000094

23


Figures

Figure 8. COLIWASA

000095



Appendix E

EPA ERT SOP 2002 Sample Documentation

000096




DATE: 10/03/94SAMPLE DOCUMENTATION

CONTENTS

1.0 OBJECTIVE

2.0 APPLICABILITY

3.0 DESCRIPTION

3.1 General3.2 Site Logbooks*3.3 Personal Logbooks3.4 Field Data Sheets and Sample Labels*

3.4.1 Field Data Sheets and Sample Labels3.4.2 Soil Gas Sampling Data Sheets and Sample Labels3.4.3 Air Sampling Work Sheets and Sample Labels3.4.4 Specialized Field Data Sheets

3.5 Chain of Custody*3.6 Custody Seals

4.0 RESPONSIBILITIES

4.1 Task Leaders and Field Staff4.2 Group Leaders and Section Leaders*4.3 Quality Assurance Office

5.0 APPENDIX

A - Figures

* These sections affected by Revision 0.0.

SUPERCEDES: SOP #2002; Revision 2.0; 05/17/93; U.S. EPA Contract 68-03-3482.

000097





1.0 OBJECTIVE

The objective of this Standard Operating Procedure (SOP) is to define the procedures for preparing andmaintaining documentation which provides the details of field sampling activities. The sample documentationdiscussed in this procedure includes: site and personal logbooks, Field Data Sheets and labels, and Chain ofCustody records and Custody seals.

2.0 APPLICABILITY

This SOP is applicable to all REAC field activities which involve the generation of environmentalmeasurements.

3.0 DESCRIPTION

3.1 General

Accurate sample documentation is essential for proper site evaluation. A clear traceable paper trailmust follow each sample from its point of origin to the Final Report (or other appropriate report). Itis important that specific procedures be adopted so that the desired degree of accuracy is achieved.

All sample documents must be completed legibly and in ink. Any corrections or revisions must bemade by lining through the incorrect entry and initialing the error.

3.2 Site Logbook

The site logbook is used to record data and observations so that an accurate account of fieldoperations can be reconstructed in the writer's absence. There is the potential, especially onSuperfund sites, for site logs to be used as legal evidence sometime in the future. The site logbookis essentially a descriptive notebook detailing site activities and observations. All entries should bedated and signed by the individual(s) making the entries. Site logbooks should contain at a minimum,the following information:

C Site name and location on inside coverC Date and location of field workC Times (military times preferred, or reference a.m. or p.m.)C Names and addresses of field contactsC Site sketches and photographic referencesC Weather conditions (Optional if provided on Field Data Sheets. See Section 3.1.)C Sample descriptions, locations, times taken, identification numbers (Optional if provided on

Field Data Sheets. See Section 3.4.1.)C Chain of Custody information, shipping paper identification number, recipient address, and

phone number, etc.

000098





C Field observations and discussion (Optional if provided on Field Data Sheets. See Section3.4.1.)

C Field measurements (i.e., pH, temperature, surface water flow rates, etc.) (Optional ifprovided on Field Data Sheets. See Section 3.4.1.)

C Instructions issued by the Work Assignment ManagerC Field activities by all REAC personnel on site

Entries may be made in site logbooks by any ERT or REAC personnel on site and should detail theactivities of all personnel involved in the field operations. Each entry should be signed by the personmaking the entry and should relate to previous entries or have sufficient background detail. Thesequence of site activities should be clear to a reader who was not at the site.

When a site logbook is completed, no longer needed for site documentation, or after a project isfinished, the site logbook must be transmitted to the appropriate Work Assignment folder of theCentral File. If the site logbook is transmitted to the ERT, documentation of the transmittal must beprepared and maintained in the Central File.

3.3 Personal Logbooks

When involved in field operations, all REAC personnel will maintain a personal logbook. Thepersonal logbook will be a chronological compilation of the individual's daily field activities.Personal logbooks are to be maintained, even if a REAC member is entering information in a site log.The personal logbook may reference the site logbook, but must also identify what, if any, work wasperformed when not on site. In the absence of a dedicated site logbook, the personal logbook mustdetail all site related activities that would typically be entered in a site logbook.

If personal logbooks are used for site-related information in lieu of a dedicated site logbook, theREAC Task Leader must obtain copies of the site notes from each individual field member andtransmit the notes under a standard cover memo (Figure 1, Appendix A) to the Central File. Thismust be done within 10 working days of completion of field activities.

Personal logbooks may be maintained for the individual's daily office activities at the discretion ofthe individual. When a REAC member is in the office, the personal logbook should contain, at aminimum, meetings attended and meeting notes, telephone conversations, and detail of any workperformed that relates to a particular site. Any task related entries should include the WorkAssignment number. Entries should include, but are not limited to, the following:

C Field and project-related activities performedC Directives from Work Assignment ManagerC Verbal instructions from U.S. EPA personnelC Personal injuries or potential exposuresC Phone conversations relevant to Work Assignments

000099





When a personal logbook is completed or the person to whom it is assigned leaves REAC, thepersonal logbook shall be returned to the Quality Assurance (QA) Office. People who must accessinformation in a personal logbook may obtain photocopies from the person to whom the logbook isassigned.

3.4 Field Data Sheets and Sample Labels

Field Data Sheets and corresponding sample labels are used to identify samples and document fieldsampling conditions and activities. There are several different Field Data Sheets and sample labelsused within the REAC project.

Field Data Sheets will be maintained by the Task Leader or designee. Task Leaders are responsiblefor conveying original Field Data Sheets to the corresponding Central File folder upon completionof the Trip or Final Report. Field Data Sheets may be transmitted to the Central File as an attachmentto these reports or as a stand alone document.

3.4.1 Field Data Sheets and Sample Labels

Prenumbered Field Data Sheets and corresponding, prenumbered sample labels (Figures 2and 3, Appendix A) are used for all types of samples except soil gas and air samples (seeSections 3.4.2 and 3.4.3).

Upon sample collection at a particular sampling location, Field Data Sheet(s) shall becompleted with the following information:

1. Site name, sampling location, date and time of sampling, name(s) of sampler(s),Chain of Custody record number, REAC Task Leader's name, U.S. EPA WorkAssignment Manager's name, and the Work Assignment number.

2. Site description and, as applicable, soil type, surface water, stream, and bottominformation.

3. Sample type, sampling device, sample information (e.g., color, odor, temperature,pH, etc.) and weather parameters.

4. Analyses to be performed and sample preparation information.

Also upon sample collection, the corresponding prenumbered sample labels must becompleted and securely affixed to the sample container(s).

Because samples are often collected from the same location in more than one container (formore than one analysis), the sample label consists of several parts (Figure 3, Appendix A).The largest part of the sample label consists of the project name and U.S. EPA contractnumber, the unique sample identification number consisting of the prefix "A" followed bya five-digit number (A01001), and spaces for inserting the following information: site name,

000100





work order number, date and time of collection, the analysis requested, and the preservative.Other parts of the sample label include additional sample labels numbered with the samesample identification number and consecutive letter prefixes (B01001 to L01001).

When a sample is collected in only one container, the largest part of the sample label iscompleted and affixed to the sample container. When the sample is collected in multiplecontainers, the largest part of the sample label is completed and affixed to one of the samplecontainers, and the additional labels, beginning with letter prefix "B," are affixed to theadditional containers in a consecutive order. If more than 12 containers are included in asample set, then the sampler may use blank labels and insert the sample identificationnumber beginning with letter prefix "M" (M01001).

If duplicates or blanks are collected at a sampling location, the sample sets must be treatedas being unique from the original sample and labeled with different sample identificationnumbers. When collecting samples for parameters which require extra volume for matrixspike/matrix spike duplicate (MS/MSD) analysis, the original sample container(s) and theMS/MSD containers are labeled with the same sample identification number and consecutiveletter prefixes. For example, a water sample for BNA analysis that also requires MS/MSDanalysis would be collected in four sample containers which would be labeled A01003through D01003. Required volumes for MS/MSD analysis for typical parameters arespecified in ERT/REAC SOP #4005, Chain of Custody.

3.4.2 Soil Gas Sampling Data Sheets and Sample Labels

Soil Gas Sampling Data Sheets and prenumbered sample labels (Figure 4 and 5, AppendixA) are used for all soil gas sampling activities.

The heading of the data sheets shall be completed with the following information: site name,samplers, date, REAC Task Leader, U.S. EPA Work Assignment Manager, the projectnumber, and the weather parameters.

After the soil gas well is screened with field instrument(s), the location identification,pertinent remarks, time, depth, and the instrument reading(s) are recorded in the firstavailable column on the Soil Gas Sampling Data Sheet. A total of five (5) columns areavailable to record data from five sampling points on each Data Sheet.

If a soil gas sample was collected at that particular location, "Y" is circled to indicate this.The soil gas sample label is completed with the site name, sample location, date, time,remarks, and instrument readings; then the label is affixed to the sample container. Acorresponding sample label (with sample identification number only) is inserted on thesample number line in the appropriate column on the soil gas sampling data sheet. If a soilgas sample was not collected at that particular location, "N" is circled to indicate this.

If necessary, the additional sample label (with the sample identification number only) canbe inserted in the logbook used for documenting sampling activities, or it can be used for

000101





additional sample containers if the sample is collected in multiple containers. Blank samplelabels are also provided so that sample numbers can be written in, when needed. Tripstandards, field blanks, and samples containing spikes must be assigned unique sampleidentification numbers. Soil Gas Sampling Data Sheets and sample labels will be preparedand maintained for these types of samples in the same manner as other sample matrices.

3.4.3 Air Sampling Work Sheets and Sample Labels

Air Sampling Work Sheets and prenumbered sample labels (Figures 6 and 7, Appendix A,respectively) are used for all air sampling activities.

The heading of the Air Sampling Worksheet is completed with the following information:site name, samplers, date, Work Assignment number, the name of the U.S. EPA WorkAssignment Manager, and the REAC Task Leader.

When air sampling is initiated, the following information is recorded in the first availablecolumn on the Air Sampling Worksheet: sample number, location, pump number media,analysis/method and time/counter start. At the end of the sampling period the followinginformation is recorded: time/counter stop, total time, pumpfault (indicate by using "Y" or"N"), flow rate start, flow rate stop, flow rate average, and volume, are recorded. A total offive columns are available to record data from five sampling locations on each air samplingworksheet.

The total sampling time is calculated by subtracting the start time/counter value from thestop time/counter value. The flow rate average is calculated from the start and stop flowrates. The volume sampled is calculated by multiplying the total sampling time by theaverage flow rate. All calculated values, along with the analysis requested, are recorded inthe appropriate location on the air sampling worksheets.

If real-time air monitoring instruments are used at a particular sample location, theinstrument readings are recorded on an Air Monitoring Work Sheet (Figure 8, Appendix A).If air samples are collected outdoors, then the appropriate weather parameters are alsorecorded on the Air Monitoring Work Sheet.

The prenumbered air sample label (Figure 7, Appendix A) consists of several parts. Thelargest part includes the project name, the contract number, the sample identificationnumber, and space for the following information: the site name, volume of air, date, time,requested analysis, and remarks. Other parts include two additional sample labels with onlythe sample identification number.

When a sample is collected, the largest part of the sample label is completed and affixed tothe sample container in the manner described by the appropriate ERT/REAC air samplingSOP. If samples are collected from a single sampling location in more than one samplemedia, separate sample numbers are used for each different sample medium used. The blankspace at the end of the sample identification number is used to indicate the media. The small

000102





sample labels are affixed to the additional sample containers. If available, the small samplelabels may be inserted in the sample number space in the appropriate column on the AirSampling Work Sheet. Blank sample labels are provided for use as necessary.

Alternatively, at the Task Leader's discretion, separate sample numbers may be used for eachmedia in which samples are collected at a single sampling location. In this case, the largestpart of the sample label will be completed and affixed to the sample container in the mannerdescribed by the appropriate ERT/REAC air sampling SOP. The small sample labels (withsample identification number only) will be affixed to the Air Sampling Worksheet and thelogbook.

Quality Control (QC) samples must be assigned unique sample identification numbers. AirSampling Work Sheets and prenumbered sample labels will be prepared and maintained inthe same manner as for other sample matrices.

3.4.4 Specialized Field Data Sheets

Task Leaders, with the approval of the Group Leader, the Work Assignment Manager, andthe QA Officer, may develop specialized Field Data Sheets if none of the three typesdescribed above meet the specific needs of the project. At a minimum, the Field Data Sheetmust include space for recording the name(s) of the sampler(s), the sample number(s), thelocation of the sample, the date and time that the sample was taken, and any pertinent fieldconditions. The following information will be included in the header of the data sheet:(Matrix) Data Sheet, Roy F. Weston, Inc., REAC, Edison, NJ, U.S. EPA Contract: 68-C4-0022.

3.5 Chain of Custody

A Chain of Custody record (Figure 9, Appendix A) must be maintained from the time a sample iscollected to its final deposition. The Chain of Custody record shall contain, at a minimum, thefollowing information: project name, project number, the REAC contact, and the contact telephonenumber. For each sample collected, the Chain of Custody record shall include the sample number,sampling location, sample matrix, date collected, number of bottles, container/preservative, theanalysis requested, and special instructions, if any are applicable.

Chain of Custody records must be completed legibly, with all required information, so thatmiscommunication with, or misunderstanding by, the receiving laboratory is prevented.

If samples collected during a sampling event are being forwarded to more than one laboratory, thena separate Chain of Custody record, indicating which samples are being sent to that particularlaboratory, must be completed.

The Chain of Custody provides a means by which the entire path and life of a sample can be traced.Every transfer of custody must be noted and signed for on the Chain of Custody record. If a sampleor group of samples is not under direct control or observation of the individual responsible for the

000103





samples, then they must be stored in a locked container that has been sealed with a Custody Seal(Section 3.6). A copy of the Chain of Custody record should be kept by each individual who hassigned it. The final copy should be included with the Analytical Report.

3.6 Custody Seals

Custody Seals (Figure 10, Appendix A) demonstrate that a sample container has not been opened ortampered with during transport or storage. Two seals should be affixed in such a manner that theshipping container cannot be opened without breaking the seal. The person in direct possession ofthe samples shall sign and date the seal. The name of the individual signing the seal and a descriptionof the packaging shall be noted in the site logbook.

4.0 RESPONSIBILITIES

4.1 Task Leaders and Field Staff

Task Leaders and field staff are responsible for preparing and maintaining sample documentation inaccordance with this SOP.

4.2 Group Leaders and Section Leaders

Group Leaders and Section Leaders are responsible for ensuring implementation of the proceduresoutlined in this SOP.

4.3 QA Office

The QA Office is responsible for ensuring compliance with this SOP by auditing reports prepared byREAC personnel.

000104





APPENDIX AFigures

SOP #2002September 1994

000105





FIGURE 1. Cover Memo - Transmittal of Site Notes

DATE:

TO: Central File #

FROM: , Task Leader

SUBJECT: LOGBOOK NOTESSITE NAME, DATE(s)

Attached please find copies of field-related personal logbook records for activities performed at the above- referencedsite. Individuals involved included:

NAME LOGBOOK NUMBER

w/Attachments

000106





FIGURE 2. Field Data Sheet

000107





FIGURE 3. Sample Labels

000108





FIGURE 4. Soil Gas Sampling Data Sheet

000109





FIGURE 5. Soil Gas Sample Labels

000110





FIGURE 6. Air Sampling Work Sheet

000111





FIGURE 7. Air Sample Labels

000112





FIGURE 8. Air Monitoring Work Sheet

000113





FIGURE 9. Chain of Custody Record/Lab Work Request

000114





FIGURE 10. Custody Seals

000115



Appendix F

EPA ERT SOP 2049 Investigation-Derived Waste Management

000116




DATE: 10/21/94INVESTIGATION-DERIVED WASTE MANAGEMENT

CONTENTS


2.0 METHOD SUMMARY

3.0 SAMPLE PRESERVATION, CONTAINERS, HANDLING AND STORAGE



5.1 Waste Disposal5.2 Decontamination Equipment

6.0 REAGENTS

7.0 PROCEDURES

7.1 Regulatory Background and Options for Management of IDW7.2 Identification of IDW7.3 Management of IDW

7.3.1 Waste Minimization7.3.2 Types, Hazards, and Quantities of IDW7.3.3 On-Site IDW Handling Options7.3.4 Off-Site Disposal of IDW Options

8.0 CALCULATIONS




12.0 REFERENCES

SUPERCEDES: SOP #2170; Revision 0.0; 03/22/94; U.S. EPA Contract 68-03-3482.

000117






The objective of this standard operating procedure (SOP) is to provide general reference information onmanagement of investigation-derived wastes (IDW) generated during REAC site investigations. IDW includessoil cuttings, drilling muds, purged groundwater, decontamination fluids (water and other fluids), disposablesampling equipment, and disposable personal protective equipment (PPE).

This SOP is applicable only if the U.S. Environmental Protection Agency (U.S. EPA) On-Scene Coordinator,Remedial Project Manager, or other Regional Manager does not have procedures in place for IDWmanagement.

These are standard (i.e., typically applicable) operating procedures which may be varied or changed asrequired, dependent upon site conditions, equipment limitations or limitations imposed by the procedure. Inall instances, the ultimate procedures employed should be documented and associated with the final report.

Mention of trade names or commercial products does not constitute U.S. EPA endorsement or recommendationfor use.

2.0 METHOD SUMMARY

Prior to site activities, the Task Leader should determine if the On-Scene Coordinator, Remedial ProjectManager, or other Regional Manager has procedures in place for IDW management. This should be done bycontacting the Work Assignment Manager.

If it is determined that procedures are not in place, then the Task Leader should evaluate IDW handling andmanagement options based on:

C The site contaminants and their concentrations, and total projected volume of IDW.C Media potentially affected (e.g., groundwater, soil) by management options.C Location of the nearest population(s) and likelihood and/or degree of site access.C Potential exposure to workers.C Potential environmental impacts.

Every effort must be made to ensure the selection of investigation method(s) that minimize the generation ofIDW, contact with contaminants, and cost of disposal. Efforts made to characterize IDW shall be consistentwith the scope and purpose of the site investigation.

The QA Work Plan describing the anticipated approach and procedures for IDW management shall be clear,detailed, and concise. Any deviation or modification due to unexpected and unforeseen field conditions willbe noted in the site logbook.

000118





3.0 SAMPLE PRESERVATION, CONTAINERS, HANDLING AND STORAGE



IDW can be contaminated with various hazardous substances. To handle IDW in compliance with regulations,reasonable efforts should be made to characterize the wastes.


Equipment, materials, and supplies needed for containerizing IDW are generally selected based on wastecharacteristics or constituents. Other considerations include the case of decontaminating or disposing of theequipment. Most equipment and supplies can be easily procured. For example, 5-gallon buckets, plastic bags,etc. can help segregate contaminated materials. Contaminated liquid can be stored temporarily in metal orplastic cans or drums.

5.1 Waste Disposal

C Trash bags

C Trash containers

C 55-gallon drums or 5-gallon pails

C Metal/plastic buckets/containers for storage and disposal of decontamination solutions

5.2 Decontamination Equipment

C Drop cloths of plastic or other suitable materials

C Large galvanized tubs

C Wash solutions

C Rinse solutions

C Long-handled, soft-bristled brushes

C Paper or cloth towels

C Metal or plastic cans or drums

C Soap or wash solution

000119





6.0 REAGENTS

There are no reagents used in this procedure aside from decontamination solutions. In general, the followingsolvents are typically utilized for decontamination purposes:

C 10% nitric acid C Acetone (pesticide grade)C Hexane (pesticide grade)C Methanol

7.0 PROCEDURES

7.1 Regulatory Background and Options for Management of IDW

This SOP is based on the following guidance document:

OERR Directive 9345.3-02, "Management of Investigation-Derived Wastes During Site Inspections,"May 1991.

The guidance document presents a general regulatory background and options for management ofIDW generated during Superfund site activities. IDW includes soil cuttings, drilling muds, purgedgroundwater, decontamination fluids (water and other fluids), disposable sampling equipment anddisposable PPE. The National Contingency Plan (NCP) requires that management of IDW generatedduring site investigations complies with all applicable or relevant and appropriate requirements(ARARs) to the extent practicable. In addition, other legal and practical considerations may affectthe handling of IDW.

IDW from site inspections may contain hazardous substances as defined by the ComprehensiveEnvironmental Response, Compensation, and Liability Act (CERCLA). Some CERCLA hazardoussubstances are hazardous wastes under Subtitle C of the Resource Conservation and Recovery Act(RCRA), while other substances are regulated by other federal laws such as the Safe Drinking WaterAct (SDWA), Clean Air Act (CAA), Toxic Substances Control Act (TSCA), and the Clean WaterAct (CWA). The U.S. EPA estimates that RCRA hazardous IDW have been generated at fewer than15% of CERCLA sites. However, RCRA regulations, and in particular the RCRA Land DisposalRestrictions, are very important as potential ARARs since they regulate treatment, storage, anddisposal of many of the most toxic and hazardous materials.

The U.S. EPA's strategy for managing RCRA hazardous IDW is based on:

C The NCP directive that site investigations comply with ARARs to the extent practicable.C The area of contamination (AOC) unit concept.

000120





The most important general elements of managing IDW are as follows:

C Leaving a site in no worse condition than existed prior to the investigation.C Removing those wastes that pose an immediate threat to human health or the environment.C Leaving on site those wastes that do not require off-site disposal or long-term above-ground

containerization.C Complying with federal and state ARARs to the extent practicable.C Planning and coordination for IDW management.C Minimizing the quantity of wastes generated.

The specific elements of the approach are as follows:

C Characterizing IDW through the use of existing information (manifests, Material Safety DataSheets, previous test results, knowledge of the waste generation process, and other relevantrecords) and best professional judgement.

C Delineating an AOC unit for leaving RCRA hazardous soil cuttings within the unit.C Containerizing and disposing of RCRA hazardous groundwater, decontamination fluids,

PPE, and disposable sampling equipment (if generated in excess of 100 kg/month) at RCRASubtitle C facilities.

C Leaving on site RCRA nonhazardous soil cuttings, groundwater, and decontamination fluidspreferably without containerization and testing.

The U.S. EPA does not recommend the removal of wastes from all sites and, in particular, from thosesites where IDW does not pose any immediate threat to human health or the environment.

Based on this information and the guidelines included in the following sections, the REAC TaskLeader should include a plan for handling IDW in the QA Work Plan. Any deviations from ormodifications to the plan due to unexpected or unforeseen field conditions must be noted in the sitelogbook.

7.2 Identification of IDW

To handle IDW properly, the Task Leader must know whether it contains CERCLA hazardoussubstances and whether these substances are RCRA hazardous wastes or contaminants regulatedunder other statutes. To handle IDW in compliance with regulations, reasonable efforts should bemade to characterize them. However, these efforts should be consistent with the scope and purposeof the site investigation.

In particular, extensive testing is not warranted in most cases; instead, the nature of the wastes shouldbe assessed by applying professional judgement, using readily available information about the site(such as manifests, storage reports, preliminary assessments, and results of earlier studies), as wellas direct observation of the wastes for discoloration, odor, or other indicators of contamination.Similarly, RCRA procedures for determining whether a waste exhibits RCRA hazardouscharacteristics do not require testing if the decision can be made by applying knowledge of the

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characteristic in light of the materials or process used. In most instances, a determination may bemade based on available information and professional judgement. This does not mean that IDW canbe assumed to be nonhazardous unless clearly proven otherwise. Given the limited informationavailable, the Task Leader, in conjunction with the Work Assignment Manager, must determinewhether it more likely than not that the wastes are hazardous.

Even if the IDW do not contain RCRA hazardous waste, the Task Leader should determine whetherthey contain other CERCLA hazardous substances. CERCLA hazardous substances include, inaddition to RCRA hazardous wastes, substances, elements, compounds, solutions, or mixturesdesignated as hazardous or toxic under CERCLA itself or under the authority of other laws such asTSCA, CWA, CAA, and SDWA. Therefore, even if RCRA is not applicable, one of these statutesmay be.

IDW may include, but is not limited to, the following items:

Solid Waste

C SoilC SedimentC Sludge/slagC Drum solidsC Drill cuttingsC Used glasswareC Dedicated/expendable equipment (bailers, fitters, hose, buckets, XRF cups, etc.)C Biological tissueC Clean trashC PPEC Decontamination equipment (buckets, brushes, clothing, tools, etc.)C Field analytics waste (immunoassay, chlor-n-oil, chlor-in-soil, HACH kits, sample extracts,

etc.)

Aqueous Waste

C Drilling fluidsC Purge waterC Development waterC Decontamination fluids

7.3 Management of IDW

7.3.1 Waste Minimization

The Task Leader should select site investigation methods that minimize the generation ofIDW, particularly RCRA hazardous wastes. The site investigation team should limit contact

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with contaminants and use drilling and decontamination methods (such as steam cleaning)that minimize PPE, disposable equipment, decontamination fluids, and soil cuttings. Inparticular, the inspection team should minimize the amounts of solvents used fordecontamination or eliminate solvents altogether. Minimizing the amount of wastesgenerated reduces the number of IDW handling problems and costs of disposal.

7.3.2 Types, Hazards, and Quantities of IDW

To handle IDW properly, the Task Leader must determine the types (such as soil cuttings,groundwater, decontamination fluids, PPE, or disposable equipment), characteristics(whether RCRA hazardous or containing other CERCLA hazardous substances), andquantities of anticipated wastes. As discussed previously, testing will generally not berequired to characterize waste.

Upon determining the types of anticipated IDW, the Task Leader should determine IDWcharacteristics, in particular whether it is expected to be RCRA hazardous or to contain highconcentrations of PCBs. For RCRA hazardous IDW, the Task Leader should determinewhether it poses an increased hazard to human health and the environment relative toconditions that existed prior to the site investigation. Field analytical screening results, ifavailable, may be helpful indicators of IDW characteristics. However, the Task Leader mustremember that these are not RCRA tests and that the test results usually do not identifyRCRA hazardous wastes. The Task Leader must also determine the exact properties ofRCRA nonhazardous IDW to select an appropriate disposal facility when the off-sitedisposal is required.

Upon determining the type and characteristics of IDW to be generated, the Task Leader mustassess the anticipated quantities of waste. This should be done based on past experiencewith site investigations of similar scope.

7.3.3 On-Site IDW Handling Options

In planning the scope of work, the Task Leader must decide if IDW can be left on site or ifit must be disposed off site.

Handling of RCRA hazardous IDW and IDW with high PCB concentrations (greater than50 ppm) may involve either moving the IDW within an AOC unit, or containerization,storage, testing, treatment, and off-site disposal. Handling of RCRA nonhazardous IDWusually involves various methods of on-site disposal. It is preferable to leave both RCRAhazardous and nonhazardous IDW on site whenever it complies with regulations and doesnot pose any immediate threat to human health and the environment.

If IDW are RCRA nonhazardous soil or water, they should be left on site unless othercircumstances, such as state ARARs or a high probability of serious community concerns,require off-site disposal. RCRA hazardous soil also may be left on site within an AOC unit.

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The Task Leader must determine procedures for handling IDW on site in conjunction withthe Work Assignment Manager.

The on-site handling options available to the Task Leader when IDW are RCRAnonhazardous are listed below.

For soil cuttings:

1. Spread around the well.2. Put back into the boring.3. Put into a pit within the AOC.4. Dispose of at the site's operating treatment/disposal unit (TDU).

For groundwater:

1. Pour onto ground next to well to allow infiltration.2. Dispose of at the site's TDU.

For decontamination fluids:

1. Pour onto ground (from containers) to allow infiltration.2. Dispose of at the site's TDU.

For decontaminated PPE and disposable equipment:

1. Double bag and deposit in the site or U.S. EPA dumpster, or in any municipallandfill.

2. Dispose of at the site's TDU.

If IDW are considered RCRA nonhazardous due to lack of information on the waste hazard,the Task Leader should have an alternate plan for handling IDW if field conditions indicatethat these wastes are hazardous. In such a case, there should be an adequate number ofcontainers available for collecting groundwater, decontamination water, soil cuttings, etc.

If IDW consists of RCRA hazardous soils that pose no immediate threat to human health andthe environment, the Task Leader should plan on leaving it on site within a delineated AOCunit. However, the Task Leader must consider the proximity of residents and workers in thesurrounding area and use best professional judgement to make these decisions. Planning forleaving RCRA hazardous waste on site involves:

C Delineating the AOC unit.C Determining pit locations close to the borings within the AOC unit for waste burial.C Covering hazardous IDW in the pits with surficial soil.C Not containerizing and testing wastes designated to be left on site.

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Another alternative for handling RCRA hazardous soil is disposal in a TDU located on thesame property as the AOC under investigation. If the TDU is outside the AOC, it mustcomply with the off-site policy. If any decontamination fluids are generated which areRCRA hazardous wastes, they should be disposed of off site in compliance with the off-sitepolicy or in compliance with the conditionally exempt small quantity generator exemption.Small quantities (i.e., no more than 100 kg/month) of decontamination fluids may becontainerized prior to delivery to a hazardous waste facility.

7.3.4 Off-Site Disposal of IDW Options

IDW should be disposed of off site in the following situations:

C When they are RCRA hazardous water.C When they are RCRA hazardous soil that may pose a substantial risk if left at the

site.C When they are RCRA hazardous PPE and disposable equipment.C If leaving them on site would create increased risks at the site.

RCRA nonhazardous wastes could be disposed of off-site at appropriate RCRAnonhazardous facilities that are in compliance with CERCLA section 121(d)(3) and off-sitepolicy when it is necessary to comply with legally enforceable requirements such as stateARARs that preclude on-site disposal. IDW designated for off-site disposal must beproperly containerized, tested, and stored before pick up and disposal. Decontaminated PPEand disposable equipment should be double-bagged if sent to an off-site dumpster ormunicipal landfill.

Planning for off-site disposal should include the following guidelines:

C Informing the Work Assignment Manager that containerized IDW may betemporarily stored on site while awaiting pick up for off-site disposal.

C Initiating the procurement process for IDW testing, pick up and disposal.C Coordinating IDW testing and pick-up activities.C Preparing adequate numbers and types of containers. Drums should be used for

collecting small amounts of IDW. Larger amounts of soil and water can becontained in Baker tanks, poly tanks, and bins. PPE and disposable equipmentshould be double-bagged for disposal at a municipal landfill or collected in drumsfor disposal at a hazardous waste facility.

C Designating a storage area (either within the site's existing storage facility, existingfenced area, or within a temporary fence constructed for the site investigation). Nohumans, children in particular, may have access to the storage area.

All IDW shipped off site, whether RCRA hazardous or not, must go to facilities that complywith the RCRA disposal policy, and the Task Leader, in conjunction with the REACPurchasing Department, must verify that the facilities operate in accordance with this policy.

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8.0 CALCULATIONS



There are no specific quality assurance activities which apply to the implementation of these procedures.However all IDW disposal information must be documented within site logbooks. Additionally, all shippingand transport of hazardous and nonhazardous samples will comply with Department of Transportation (DOT)and International Air Transport Association (IATA) regulations. For additional information regarding samplehandling procedures refer to ERT/REAC SOP #2003, Sample Storage, Preservation, and Handling.




When working with potentially hazardous materials, follow U.S. EPA, OSHA and corporate health and safetyprocedures.

12.0 REFERENCES

U.S. EPA, Guide to Management of Investigation Derived Wastes, OERR Directive 9345.3.03FS, January1992.

U.S. EPA, Management of Investigations - Derived Wastes During Site Inspections, OERR Directive 9345.3-02, May 1991.

Code of Federal Regulations (CFR), Title 40, Part 261, Section 23, Section 11 (a) (3), and Section 24 (a) (b).

CFR Proposed Criteria: 51 FR 21685, June 30,1986 and 51 FR 21450, May 20, 1992.

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